Brennan v. State

868 S.E.2d 782, 313 Ga. 345
CourtSupreme Court of Georgia
DecidedFebruary 1, 2022
DocketS21A1183
StatusPublished
Cited by1 cases

This text of 868 S.E.2d 782 (Brennan v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brennan v. State, 868 S.E.2d 782, 313 Ga. 345 (Ga. 2022).

Opinion

313 Ga. 345 FINAL COPY

S21A1183. BRENNAN v. THE STATE.

LAGRUA, Justice.

Appellant Erica Brennan was convicted of felony murder and

other crimes in connection with the scalding death of her eight-year-

old stepdaughter, Sarah Harris. On appeal, Appellant contends: (1)

the trial court erred by conducting a pre-trial conference pursuant

to Uniform Superior Court Rule (“USCR”) 33.5 (B) outside her

presence in violation of her federal and state constitutional rights;

(2) the trial court erred by initiating an ex parte conversation with

the lead detective, and by failing to disclose this conversation to

counsel; and (3) her second-chair counsel rendered ineffective

assistance by being mentally and physically incapable of assisting

in Appellant’s trial.1 For the reasons explained below, we affirm.

1 The crimes occurred on July 6, 2007. On January 8, 2008, a Long County grand jury indicted Appellant for malice murder, two counts of felony murder, cruelty to children in the first degree, and aggravated battery. On 1. The evidence presented at trial showed the following. In July

2007, Appellant was married to Russell Brennan. They lived

together with Harris, who was Brennan’s daughter, as well as

Appellant’s seven-year-old son. At the time, Brennan was a sergeant

in the United States Army, stationed at Fort Stewart but deployed

to Iraq. On the night of July 6, Brennan was en route home for two

weeks of leave.

On July 6 around 4:30 p.m., Appellant called her friend,

Jennifer Madron, whose husband was also stationed at Fort Stewart

and deployed to Iraq. According to Madron, Appellant invited

Madron and her children to Appellant’s house to go swimming, but

January 28, 2008, the State filed its notice of intention to seek the death penalty. On April 1, 2010, the State withdrew its intention to seek the death penalty. At a trial from April 5 to 8, 2010, the jury found Appellant not guilty of malice murder but guilty of the remaining counts. Appellant was sentenced to serve life in prison for felony murder and 20 years in prison for aggravated battery to be served concurrently; the remaining counts were merged for sentencing purposes. Appellant filed a timely motion for new trial, which was amended on February 20, 2019. On September 20, 2019, the trial court held an evidentiary hearing on the motion for new trial. After the hearing, supplemental briefs were filed by Appellant and the State. On April 21, 2021, the trial court denied Appellant’s amended motion for new trial. Appellant filed a timely notice of appeal, and the case was docketed to this Court’s August 2021 term and submitted for a decision on the briefs.

2 Madron declined. Around 7:30 p.m., Appellant called Madron, and

they had a 15- to 20-minute friendly, normal conversation. Ten

minutes later, Appellant called Madron, said Harris had been

burned, and asked for advice on how to “ease the pain.” Madron,

assuming Harris had been sunburned while at the pool earlier that

day, recommended pouring canned milk on Harris’s burns.

Appellant then poured canned milk on Harris. Around 8:00 p.m.,

Appellant called Madron and said Harris’s “skin was falling off.”

During this phone call, Madron heard Harris crying in the

background. Appellant and Madron agreed to meet in a parking lot

at Fort Stewart.

After parking their cars, Appellant walked around to her

passenger door, said to Madron, “Look what [Harris] did,” and

opened the passenger door. Harris was sitting in the car,

whimpering and crying, wearing shorts and a shirt, and “[a]ll her

skin was gone.” Madron insisted that Appellant take Harris to the

hospital. Appellant disagreed and wanted to treat Harris’s burns

herself. Madron threatened to call the military police, and Appellant

3 eventually agreed to take Harris to the hospital. Madron agreed to

pick up Appellant’s son.

While leaving Fort Stewart, Madron was pulled over by the

military police for using her cell phone while driving. Madron

explained the situation concerning Harris to the military police

officer and requested the U. S. Army Criminal Investigation

Division (“CID”) be sent to the hospital to investigate. The military

police officer told Madron that she would make sure CID went to the

hospital.

While Madron was picking up Appellant’s son, Appellant

carried Harris into the emergency room of the Fort Stewart hospital.

Hospital staff observed burns on 75 to 80 percent of Harris’s body;

Harris had no burns on her face, upper chest, or knees. Harris had

third-degree burns on her feet; the burns on the rest of her body were

between second- and third-degree burns. Harris’s burns were

“clearly demarcated,” meaning “that they were clearly visible, not in

an erratic pattern, but a clear pattern.” Harris had “stocking burns”

on her feet meaning there was a clear line of demarcation

4 demonstrating that her feet burned for longer than the rest of her

body. Harris also had some bruising on her lower abdomen and left

thigh; she was alert and complained about the pain she was

experiencing.

Appellant told a nurse that Harris had obtained the bruises

from “roughhousing” with Appellant’s son. Appellant had directed

Harris to take a bath, and she later found Harris lying in the water.

Appellant stated that her husband had set the water heater at 180

degrees, and Appellant never changed it. The nurse further testified

that Appellant was preoccupied with who was going to pick up her

husband from the airport that night.

While at the hospital, Appellant met with a Georgia Division

of Family and Children Services caseworker. Appellant told the

caseworker that she had directed Harris to take “a hot shower,” and

that Harris “ran her own bathwater.” Appellant also stated that

there had been “problems gauging the temperature of the water,”

and she had reported it to the landlord. Appellant further stated she

was having problems with Harris and that “when [Harris] has

5 contact with her bio[logical] mother,”2 Harris “acts out” by biting her

nails and pulling her hair out.

A military police officer also spoke with Appellant at the

hospital, and he testified that he had not observed any burns on

Appellant’s hands or arms that night. Sometime that evening,

Harris was transported to an Augusta hospital for more specialized

care.

Around 9:00 p.m., Appellant called Stacy McBride3 and told

McBride that Brennan was going to kill her because Harris “had an

accident.” Specifically, Appellant told McBride that she had directed

Harris “to run herself a warm bath” and had “third-degree burns

over 80 percent of her body.” During the course of the evening,

Appellant made 10 to 12 calls to McBride. During these calls,

Appellant: (1) informed McBride that Harris was transferred and

asked “if it would look bad if she didn’t go” to the Augusta hospital;

2 At trial, Harris’s biological mother testified that she was in jail on the

night of July 6, and she did not speak with her daughter that day. 3 McBride’s husband was the commander of Sergeant Brennan’s military

unit and was responsible for the support system involving military families.

6 (2) requested that Brennan’s flight be rerouted to Augusta; (3)

explained that Harris was bruised when Appellant “thr[ew] [Harris]

in the air” while in the pool and “grabbed [Harris] by her stomach

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868 S.E.2d 782, 313 Ga. 345, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brennan-v-state-ga-2022.