Christina Williams v. State

CourtCourt of Appeals of Georgia
DecidedAugust 1, 2017
DocketA17A1190
StatusPublished

This text of Christina Williams v. State (Christina Williams v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christina Williams v. State, (Ga. Ct. App. 2017).

Opinion

FIRST DIVISION BARNES, P. J., MCMILLIAN and MERCIER, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

August 1, 2017

In the Court of Appeals of Georgia A17A1188. MUNYE v. THE STATE. A17A1189. BRICKHOUSE v. THE STATE. A17A1190. WILLIAMS v. THE STATE.

BARNES, Presiding Judge.

These appeals arise out of the appellants’ convictions for misdemeanor traffic

offenses in the now-defunct Recorder’s Court of DeKalb County (the “DeKalb

Recorder’s Court”). In Case No. A17A1188, Adan Munye appeals the dismissal of

his motion to vacate his convictions for driving with a suspended license on the

ground that they were void. Munye also appeals the denial of his motion to vacate his

sentences for those offenses as void. In Case No. A17A1189, Brandon Brickhouse

appeals the denial of his motion to vacate his sentence for driving with a suspended

license as void, and in Case No. A17A1190, Christina Williams appeals the denial of her motion to vacate her sentences for driving without valid insurance and driving

with a suspended registration as void.1

For the reasons discussed below, we conclude that Munye was not entitled to

pursue his motion to vacate his convictions because such a motion is not an

appropriate remedy in a criminal case, and his motion could not be construed as a

timely motion in arrest of judgment or other alternative motion. We further conclude

that Munye and the other appellants were not entitled to pursue their motions to

vacate their sentences because their motions were not the proper procedural vehicles

for challenging the subject matter jurisdiction of the DeKalb Recorder’s Court over

misdemeanor traffic offenses, which is the dispositive issue in these cases.

Accordingly, we must dismiss these appeals for lack of jurisdiction.2

Case No. A17A1189

1. On June 12, 2014, Munye was issued a uniform traffic citation for

committing the misdemeanor traffic offense of driving with a suspended license in

1 The appellants did not include enumerations of error in their briefs in violation of Court of Appeals Rule 22 (a) and Rule 25 (a) (2). Nevertheless, we will address the appellants’ arguments to the extent that we are able to discern them from their notices of appeal and the record. See OCGA § 5-6-48 (f). 2 The appeals were originally filed in the Supreme Court of Georgia, which transferred them to this Court.

2 violation of OCGA § 40-5-121 (a). On June 19, 2014, Munye was issued another

uniform traffic citation for committing the same offense.

Munye was tried for the June 19 misdemeanor traffic offense in a bench trial

before the DeKalb Recorder’s Court on September 2, 2014. He was found guilty and

sentenced to 12 months (with the first 5 days in custody and the remainder on

probation), and ordered to pay a $600 fine and other fees.3

In late September 2014, for reasons somewhat unclear in the record, Munye

was taken into custody for the June 12 misdemeanor traffic offense. On October 7,

2014, Munye appeared before the DeKalb Recorder’s Court, entered a plea of nolo

contendere, and was sentenced to time already served in jail.

Following his convictions and sentences, Munye did not file an application for

a writ of certiorari to the Superior Court of DeKalb County within 30 days of the final

determination of his cases in DeKalb Recorder’s Court. See OCGA §§ 5-4-3; 5-4-6

(a).4 Several months later, in June 2015, Munye filed a motion in DeKalb Recorder’s

3 Munye also was sentenced to three days to serve (to run concurrently with his five-day sentence) for contempt of court for being disruptive in court and disobeying an order to cease talking. 4 Application for a writ of certiorari pursuant to OCGA § 5-4-3 was the appropriate procedure for obtaining direct review of a final decision of the DeKalb Recorder’s Court. See Smith v. Gwinnett County, 247 Ga. App. 888, 889 (1) (545

3 Court seeking “relief for lack of subject matter jurisdiction” and requesting that his

two convictions and sentences for the misdemeanor traffic offense of driving with a

suspended license be vacated as void ab initio.

In his motion, Munye contended that both of his underlying convictions and

sentences were void and should be vacated because the DeKalb Recorder’s Court

lacked subject matter jurisdiction to adjudicate and impose punishment for

misdemeanor state traffic offenses. According to Munye, the DeKalb Recorder’s

Court purported to exercise jurisdiction over all misdemeanor state traffic offenses,

which was inconsistent with the 1959 local act that created the court and the Georgia

Constitution of 1983. Munye asserted that under the local act and the Georgia

Constitution, the DeKalb Recorder’s Court had jurisdiction to adjudicate county

ordinance violations and certain state traffic laws if adopted into the county’s

ordinances, but not jurisdiction “to enforce state law as such,” as the court had done

in his two cases. Munye also argued that his sentences were void because they

exceeded the punishment that could be imposed by the DeKalb Recorder’s Court for

SE2d 147) (2001). See also DeKalb County Code of Ordinances, Appx. B, Local Constitutional Amendments, Local Acts and General Laws of Local Application, Art. XII, Div. 2, § 670 (“Review of any final order or judgment of said recorder’s court shall be by certiorari to the superior court of DeKalb County in the manner prescribed by law for certiorari from justice courts . . . .”).

4 county ordinance violations found in the DeKalb County Code of Ordinances. Munye

alleged that he had spent time in jail, had paid improper fines and costs, and

continued to have his license suspended by the Georgia Department of Driver

Services because of his unlawful convictions and sentences.

The State opposed Munye’s motion and sought to have it dismissed. The State

argued that Munye’s convictions were final and no longer subject to direct appeal,

that Munye’s motion to vacate his judgment of conviction was not an appropriate

remedy in a criminal case, and that Munye’s motion could not be construed as a

timely filed motion in arrest of judgment or other alternative motion for seeking

redress for allegedly void convictions. The State further argued that Munye’s

purported challenge to his sentences as void was in effect a challenge to his

convictions and thus was procedurally improper.

Munye’s motion was heard by a state court judge because of new legislation

abolishing the DeKalb Recorder’s Court.5 Following a hearing, the state court entered

5 In 2015, the General Assembly enacted legislation creating a new Traffic Division of the State Court of DeKalb County to hear all cases involving violations of the state traffic laws in that county. Ga. L. 2015, p. 3501 et seq. The Recorder’s Court of DeKalb County was abolished and all pending actions relating to the violation of traffic offenses were transferred to the Traffic Division of the State Court of DeKalb County. Ga. L. 2015, pp. 3501, 3504.

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Bluebook (online)
Christina Williams v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christina-williams-v-state-gactapp-2017.