Christopher Shawn Shriver v. State

CourtCourt of Appeals of Georgia
DecidedMay 15, 2024
DocketA24A0068
StatusPublished

This text of Christopher Shawn Shriver v. State (Christopher Shawn Shriver 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
Christopher Shawn Shriver v. State, (Ga. Ct. App. 2024).

Opinion

SECOND DIVISION MILLER, P. J., MARKLE and LAND, 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. https://www.gaappeals.us/rules

May 15, 2024

In the Court of Appeals of Georgia A24A0068. SHRIVER v. THE STATE.

MILLER, Presiding Judge.

Christopher Shawn Shriver appeals from the trial court’s order denying his

motion to dismiss this criminal case based on an alleged violation of his constitutional

right to a speedy trial. Because the court did not abuse its discretion in weighing the

four-factor balancing test for constitutional speedy trial claims, we affirm.

On October 16, 2017, Shriver was allegedly involved in a physical altercation

with another man at an office of the Division of Family and Children Services.

According to the State and five witnesses who provided written statements shortly

after the incident, Shriver approached the alleged victim, punched him in the face, and

bit off his ear, all in the presence of a one-year-old child. However, according to two other witnesses who provided written statements shortly after the incident, the alleged

victim threw the first punch.

Shriver was arrested shortly after the incident and released on bond the next

day. Shriver was charged by indictment in December 2018 with simple battery (OCGA

§ 16-5-23 (a)), aggravated battery (OCGA § 16-5-24 (a)), and cruelty to children in the

third degree (OCGA § 16-5-70 (d)). In March 2019, the State provided Shriver with

discovery, including a list of witnesses to the incident and their written statements,

addresses, and telephone numbers. Shriver waived formal arraignment and pled not

guilty.

In August 2021, Shriver waived his right to a jury trial and requested a bench

trial. The trial court scheduled a bench trial for September 20, 2021. However, on

September 2, 2021, Shriver changed his mind and demanded a jury trial.

Shriver did not invoke his constitutional right to a speedy trial until February

7, 2023, when he filed a motion to dismiss the case based on an alleged violation of this

right.1 At a March 15, 2023 hearing on the motion to dismiss, Shriver’s counsel stated

that (1) the defense had attempted to contact the witnesses to the incident but had

1 Shriver never filed a statutory demand for speedy trial pursuant to OCGA § 17-7-170. 2 only been able to contact one inculpatory witness, and (2) Shriver had completed his

master’s degree in mental counseling but had been unable to obtain a counseling

license because of this case. The State indicated that the defense needed to provide

testimony to support counsel’s statements, and counsel called a private investigator

to testify that the defense retained him to locate and interview the witnesses but that

he had only been able to contact one inculpatory witness. Shriver, however, did not

testify at the hearing.

On June 6, 2023, the trial court denied the motion to dismiss, concluding that

Shriver’s constitutional right to a speedy trial had not been violated. As an initial

matter, the court found that the delay since Shriver’s arrest was presumptively

prejudicial such that the court needed to conduct the four-factor balancing test for an

alleged violation of the constitutional speedy trial right — specifically, the length of

the delay, the reasons for the delay, the defendant’s assertion of his right, and any

prejudice to him caused by the delay. Regarding the first factor, the court found that

the delay of over five years since Shriver’s arrest was uncommonly long and weighed

against the State. Regarding the second factor, the court found that the reasons for the

delay should be weighed only slightly against the State because: (a) there was no

3 evidence that the State had any intent to delay the case, and the delay appeared to be

the result of ordinary neglect; (b) the delay during the COVID judicial state of

emergency was neutral; (c) the delay after the judicial state of emergency was

inevitable and occurred when the courts were inundated with trial cases; and (d) when

the case had been set for a bench trial, Shriver withdrew his waiver and demanded a

jury trial.

Regarding the third factor, the trial court found that the delay by Shriver in

asserting his right to a speedy trial weighed strongly against him, explaining that he did

not invoke his right until over four years after his indictment even though he had

opportunities to do so and had been provided discovery. Regarding the fourth factor,

the court found that the prejudice to Shriver should be weighed slightly for him

because: (a) he had been out on bond since his arrest; (b) there was no evidence that

he had suffered any unusual anxiety or concern due to the delay; and (c) both parties

would face problems caused by the unavailability of witnesses and the potentially

faded memories of available witnesses. In balancing the four factors and concluding

that Shriver’s right to a speedy trial had not been violated, the court emphasized his

failure to assert his right in due course.

4 Shriver filed an application for interlocutory review, which this Court granted.

Shriver then filed this appeal, in which he argues that the trial court abused its

discretion in balancing the four-factor test. Specifically, Shriver challenges the trial

court’s assessment of the reasons for the delay, his assertion of his speedy trial right,

and the prejudice to him. We conclude, however, that the trial court did not abuse its

discretion in assessing these factors and in ultimately finding that Shriver’s speedy

trial right had not been violated.

The Sixth Amendment of the Bill of Rights guarantees that “[i]n all criminal

prosecutions, the accused shall enjoy the right to a speedy . . . trial.” U. S. Const.

Amend. VI. The Georgia Constitution of 1983 affirms that “[i]n criminal cases, the

defendant shall have . . . a speedy trial.” Ga. Const. 1983, Art. I, Sec. I, Par. XI (a).

The template for deciding all constitutional speedy trial claims under the Sixth

Amendment and the Georgia Constitution is set out in the United States Supreme

Court’s decisions in Barker v. Wingo, 407 U. S. 514 (92 SCt 2182, 33 LE2d 101)

(1972), and Doggett v. United States, 505 U. S. 647 (112 SCt 2686, 120 LE2d 520)

(1992). Ruffin v. State, 284 Ga. 52, 55 (2) (663 SE2d 189) (2008). The analysis has two

stages. Id. “First, the court must determine whether the [delay] is sufficiently long to

5 be considered ‘presumptively prejudicial.’ If not, the speedy trial claim fails at the

threshold.” (Citation omitted.) Id. “The right to a speedy trial attaches at the time of

arrest or formal accusation or indictment, whichever occurs first, and we measure the

delay from the time the right attaches.” (Citation omitted.) Singleton v. State, 317 Ga.

App. 637, 639 (1) (732 SE2d 312) (2012). “Where no trial has occurred, the length of

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Related

Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
Brannen v. State
553 S.E.2d 813 (Supreme Court of Georgia, 2001)
Harris v. State
667 S.E.2d 361 (Supreme Court of Georgia, 2008)
State v. Pickett
706 S.E.2d 561 (Supreme Court of Georgia, 2011)
State v. Porter
705 S.E.2d 636 (Supreme Court of Georgia, 2011)
Howard v. State
706 S.E.2d 163 (Court of Appeals of Georgia, 2011)
Fallen v. State
710 S.E.2d 559 (Supreme Court of Georgia, 2011)
Williams v. State
717 S.E.2d 640 (Supreme Court of Georgia, 2011)
Ruffin v. State
663 S.E.2d 189 (Supreme Court of Georgia, 2008)
Phan v. State
723 S.E.2d 876 (Supreme Court of Georgia, 2012)
State v. Buckner
738 S.E.2d 65 (Supreme Court of Georgia, 2013)
Singleton v. State
732 S.E.2d 312 (Court of Appeals of Georgia, 2012)
Henderson v. State
850 S.E.2d 152 (Supreme Court of Georgia, 2020)
Johnson v. State
885 S.E.2d 725 (Supreme Court of Georgia, 2023)
Rucker v. State
883 S.E.2d 790 (Supreme Court of Georgia, 2023)

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Christopher Shawn Shriver v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-shawn-shriver-v-state-gactapp-2024.