Chambers v. State

CourtSupreme Court of Georgia
DecidedJanuary 28, 2025
DocketS24A1005
StatusPublished

This text of Chambers v. State (Chambers 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
Chambers v. State, (Ga. 2025).

Opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: January 28, 2025

S24A1005. CHAMBERS v. THE STATE.

BOGGS, Chief Justice.

Appellant Jerry Chambers was convicted of three counts of

felony murder, predicated on fleeing or attempting to elude a police

officer, following a high-speed chase and crash in downtown

Savannah that resulted in the deaths of pedestrian Scott Waldrup

and Appellant’s passengers, Spencer Stuckey and Gabriel

Magulias. 1 Appellant was also convicted of reckless driving.

1 The crimes occurred on July 5, 2017. On August 16, 2017, a Chatham

County grand jury indicted Appellant for three counts each of felony murder, fleeing or attempting to elude a police officer, and homicide by vehicle in the first degree based on reckless driving; two counts of aggravated assault; and reckless driving. On September 19, 2018, Appellant was reindicted with the same twelve counts and two additional counts of violating the Georgia Street Gang Terrorism and Prevention Act; the original indictment was nolle prossed. The reindictment added charges against other defendants, but Appellant’s charges were severed for trial. The charges against the other defendants were related to the shooting that occurred on July 5 and to crimes committed in September 2017; the record on appeal does not reflect the disposition of those Appellant challenges only the felony murder convictions predicated

on fleeing or attempting to elude, see OCGA § 40-6-395 (a), arguing

that the evidence was constitutionally insufficient to establish an

essential element of fleeing or attempting to elude — that the

officer who gave the signal to stop was “in uniform prominently

displaying his or her badge of office,” id. As explained below, we

conclude that an essential element of the offense of fleeing or

attempting to elude is that the officer giving the signal to stop was

“in uniform prominently displaying his or her badge of office.” Id.

We also conclude that the State failed to meet its burden of

establishing that essential element beyond a reasonable doubt.

Because the State failed to present sufficient evidence of an

charges. At a trial from March 9 to 12, 2020, the jury found Appellant guilty of all counts, except for the aggravated assault and street gang counts. On August 25, 2020, the trial court entered the final disposition, sentencing Appellant to serve three concurrent life sentences in prison with the possibility of parole for the felony murder convictions and a concurrent term of 12 months in prison for reckless driving. The other counts merged or were vacated by operation of law. On August 27, 2020, Appellant filed a motion for new trial, which he amended with new counsel on January 17, 2024. After a hearing on February 20, 2024, the trial court entered an order denying the motion on February 26, 2024. Appellant filed a timely notice of appeal, and the case was docketed in this Court to the August 2024 term and orally argued on September 17, 2024. 2 essential element of the crime of fleeing or attempting to elude, the

guilty verdicts on those counts cannot stand, and thus we must

reverse the felony murder convictions that were predicated on the

underlying felonies of fleeing or attempting to elude. However,

because we are reversing the felony murder convictions, the

vehicular homicide counts, which were predicated on reckless

driving, no longer merge. Therefore, we also remand for sentencing

on the three counts of homicide by vehicle in the first degree.2

The evidence presented at trial showed that in the early

morning hours of July 5, 2017, Appellant was driving a white SUV

in the City of Savannah’s City Market area, which was crowded

with people celebrating the July 4 holiday. Passengers in

Appellant’s SUV exchanged gun fire with people on the street, and

Appellant drove away. Appellant’s SUV was spotted by Officers

Dennis Sylvester and Amanda Brooner of the Savannah Police

Department, who had finished working a “special detail,” but were

2 The maximum sentence that may be imposed on each conviction for

homicide by vehicle is 15 years. OCGA § 40-6-393 (a). 3 driving in the area in response to a “BOLO” call for the white SUV

that had been involved in the City Market shooting. The officers

turned on their emergency lights and siren and observed

Appellant’s SUV, which had its headlights and taillights turned off,

turn into an apartment complex. The officers followed Appellant’s

SUV, and tried to conduct a traffic stop, but Appellant did not stop.

Instead, with Officers Sylvester and Brooner in pursuit, Appellant

drove through the apartment complex, returned to the roadway,

and drove at speeds between 80 and 90 mph, which was more than

20 mph in excess of the posted speed limit. At times, Appellant

swerved into oncoming traffic, drove on a sidewalk, and ran a red

light. After driving in this manner for a few minutes, and without

ever turning on his lights, Appellant drove through a red light at

an intersection where pedestrians were crossing the road.

Appellant’s SUV struck and killed pedestrian Waldrup, before

spinning and crashing into a light pole on the sidewalk. Two officers

who had been on foot patrol and observed the crash, Detective

Brittany Harrell and Officer Lucas Hinds, saw Appellant in the

4 driver’s seat with his hands “at the steering wheel.” Officer Hinds

pulled Appellant from the driver’s seat of the SUV, although

Appellant told the officers that he had been a passenger.

Appellant’s front seat passenger, Stuckey, and the rear seat

passenger, Magulias, were both killed in the crash. Portions of

video footage from body cameras worn by Officers Sylvester and

Brooner and Detective Harrell, and from City-maintained

surveillance cameras located in downtown Savannah, were

admitted into evidence at trial and played for the jury. Additional

facts relevant to the question of whether Officers Sylvester and

Brooner were in uniform with a badge of office prominently

displayed are set forth in Division 2.

1. Appellant was indicted for three counts of felony murder

predicated on three counts of felony fleeing or attempting to elude

“Officer Dennis Sylvester, an officer who at the time of giving such

signal was in a uniform prominently displaying the officer’s badge

of office and the officer’s vehicle was appropriately marked showing

it to be an official police vehicle.” Appellant’s sole argument on

5 appeal is that the evidence was insufficient to support his

convictions for felony murder predicated on the underlying felonies

of fleeing or attempting to elude because there was no evidence that

Officer Sylvester was “in uniform prominently displaying his or her

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Michael Klopf
423 F.3d 1228 (Eleventh Circuit, 2005)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Ray v. State
503 S.E.2d 391 (Court of Appeals of Georgia, 1998)
Lester v. State
320 S.E.2d 142 (Supreme Court of Georgia, 1984)
English v. State
582 S.E.2d 136 (Court of Appeals of Georgia, 2003)
Solano-Rodriguez v. State
673 S.E.2d 351 (Court of Appeals of Georgia, 2009)
Casey v. State
673 S.E.2d 327 (Court of Appeals of Georgia, 2009)
Finlon v. State
491 S.E.2d 458 (Court of Appeals of Georgia, 1997)
Maxwell v. State
644 S.E.2d 822 (Supreme Court of Georgia, 2007)
Mooney v. State
471 S.E.2d 904 (Court of Appeals of Georgia, 1996)
Harrison v. Wigington
497 S.E.2d 568 (Supreme Court of Georgia, 1998)
Johnson v. State
506 S.E.2d 374 (Supreme Court of Georgia, 1998)
Phillips v. State
291 S.E.2d 776 (Court of Appeals of Georgia, 1982)
Cook v. State
350 S.E.2d 847 (Court of Appeals of Georgia, 1986)
Tauch v. State
700 S.E.2d 645 (Court of Appeals of Georgia, 2010)
Major v. State
800 S.E.2d 348 (Supreme Court of Georgia, 2017)
Calloway v. State
810 S.E.2d 105 (Supreme Court of Georgia, 2018)
Willis v. State
820 S.E.2d 640 (Supreme Court of Georgia, 2018)
Worthen v. State
823 S.E.2d 291 (Supreme Court of Georgia, 2019)
White v. State
823 S.E.2d 794 (Supreme Court of Georgia, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Chambers v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chambers-v-state-ga-2025.