Clark v. State

912 S.E.2d 593, 321 Ga. 35
CourtSupreme Court of Georgia
DecidedFebruary 18, 2025
DocketS24G0855
StatusPublished
Cited by1 cases

This text of 912 S.E.2d 593 (Clark 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
Clark v. State, 912 S.E.2d 593, 321 Ga. 35 (Ga. 2025).

Opinion

321 Ga. 35 FINAL COPY

S24G0855. CLARK v. THE STATE.

LAGRUA, Justice.

We granted certiorari in this case to determine whether the

notice requirement articulated in OCGA § 17-10-1 (a) (1) (B)1 is

————————————————————— 1 This statute provides in relevant part:

When a defendant with no prior felony conviction is convicted of felony offenses or is charged with felony offenses . . . , and the court imposes a sentence of probation or not more than 12 months of imprisonment followed by a term of probation, the court shall include a behavioral incentive date in its sentencing order that does not exceed three years from the date such sentence is imposed. Within 60 days of the expiration of such incentive date, if the defendant has paid all restitution owed; not had his or her probation revoked in the immediately preceding 24 months, or when the court includes a behavioral incentive date less than two years from the date a sentence was imposed, not had his or her probation revoked during such period; and not been arrested for anything other than a nonserious traffic offense as defined in Code Section 35-3-37, the Department of Community Supervision shall notify the prosecuting attorney and the court of such facts. The Department of Community Supervision shall provide the court with an order to terminate such defendant’s probation which the court shall execute unless the court or the prosecuting attorney requests a hearing on such matter within 30 days of the receipt of such order. The court shall set the matter for a hearing as soon as possible but not more than 90 days after receiving the order to terminate. The court shall take whatever action it determines would be for the best interest of justice and the welfare of society. OCGA § 17-10-1 (a) (1) (B) (i). mandatory, and if so, what remedy exists when the Department of

Community Supervision (“DCS”) fails to provide notice in

compliance with this statute. For the reasons that follow, we

conclude that, although the Court of Appeals erred in determining

that the notice requirement in OCGA § 17-10-1 (a) (1) (B) is directory

rather than mandatory, the Court of Appeals correctly concluded

that, even when DCS fails to comply with this notice requirement,

termination of the defendant’s sentence is not automatic, and the

trial court maintains the discretion to decide whether to terminate

the defendant’s probation. Therefore, we affirm.

1. Pertinent Facts and Procedural History

On May 18, 2017, Marvante Clark was indicted by a Henry

County grand jury for burglary, theft by receiving stolen property,

two counts of violation of the Georgia Controlled Substances Act,

OCGA § 16-13-20 et seq., obstruction of an officer, and possession of

marijuana, less than an ounce. On February 12, 2018, Clark entered

a guilty plea to all counts except one count of violation of the Georgia

Controlled Substances Act, which was nolle prossed by the trial

2 court. The trial court sentenced Clark as a first offender to a total of

ten years, with one year to be served in confinement and the

remainder to be served on probation.

On January 25, 2023, the State requested, and the trial court

issued, a warrant for Clark’s arrest, alleging that Clark violated his

probation on January 7, 2023, by committing a new offense of theft

by receiving stolen property. Clark was arrested shortly thereafter,

and in March 2023, Clark filed a motion to terminate his probation,

contending that his “probation should have terminated as a matter

of law” on February 12, 2021, under the retroactive application of

OCGA § 17-10-1 (a) (1) (B).2

In support of Clark’s motion, he asserted that his February

2018 sentencing order, which imposed “no more than twelve months

of imprisonment followed by probation,” did not include a behavioral

————————————————————— 2 When the trial court sentenced Clark as a first offender on February

12, 2018, the early termination provisions of OCGA § 17-10-1 (a) (1) (B) (i) were not yet in effect. However, the statute was amended to include those provisions in May 2021 and given retroactive effect. See Ga. L. 2021, p. 223, § 1. See also OCGA § 17-10-1 (a) (1) (B) (ii) (providing that division (a) (1) (B) (i) of the statute “is intended to be retroactive”). 3 incentive date, and pursuant to OCGA § 17-10-1 (a) (1) (B) (ii), where

a behavioral incentive date has not been included in an original

sentencing order, the “behavioral incentive date shall be three years

from the date such sentence was imposed.” OCGA § 17-10-1 (a) (1)

(B) (ii). Clark further argued that, under OCGA § 17-10-1 (a) (1) (B)

(i), if — within 60 days of the expiration of the behavioral incentive

date — the defendant has (1) paid all restitution owed; (2) not had

his or her probation revoked in the immediately preceding 24

months; and (3) not been arrested for anything other than a

nonserious traffic offense, DCS is required by the statute to “provide

the Court with an order to terminate probation.” Clark claimed that,

as of February 12, 2021 — three years from the date he was

sentenced — he “did not owe restitution, did not have his probation

revoked in the immediately preceding 24 months, and did not have

any new arrests,” but DCS did not provide the trial court with notice

of Clark’s compliance and a proposed3 order to terminate his

————————————————————— 3DCS does not have the authority to issue an order terminating a defendant’s probation, as such authority lies strictly with the trial court. See OCGA § 15-1-3. See also OCGA § 42-8-37 (b). Accordingly, any order presented 4 probation as required by law. Clark contended that, because DCS

failed to provide the requisite notice to the trial court, his probation

should have “automatically terminated” under OCGA § 17-10-1 (a)

(1) (B) (i).

The trial court heard Clark’s motion on April 4, 2023.

Following the hearing, the trial court issued a written order on April

28, 2023. In the trial court’s April 28 order, the trial court confirmed

that “no behavioral incentive date [was] included in [Clark’s]

sentencing order” and that OCGA §

Related

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Supreme Court of Georgia, 2026
State v. Greathouse
Supreme Court of Georgia, 2025

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912 S.E.2d 593, 321 Ga. 35, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clark-v-state-ga-2025.