Cooper v. State

914 S.E.2d 800, 321 Ga. 349
CourtSupreme Court of Georgia
DecidedApril 8, 2025
DocketS25A0041
StatusPublished

This text of 914 S.E.2d 800 (Cooper 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
Cooper v. State, 914 S.E.2d 800, 321 Ga. 349 (Ga. 2025).

Opinion

321 Ga. 349 FINAL COPY

S25A0041. COOPER v. THE STATE.

COLVIN, Justice.

Appellant Jaquez Cooper appeals his convictions for malice

murder and a related offense in connection with the November 28,

2018 shooting death of Rene Betancourt.1 On appeal, Appellant

contends that the superior court erred in denying his plea in bar,

which challenged the superior court’s jurisdiction under OCGA § 17-

1 On April 18, 2019, a DeKalb County grand jury returned a true bill of

indictment, charging Appellant with malice murder and possession of a firearm during the commission of a felony. On February 25, 2020, a DeKalb County grand jury returned a superseding indictment, which charged Appellant with malice murder (Count 1), felony murder (Count 2), aggravated assault (Count 3), possession of a firearm during the commission of a felony (Count 4), and theft by taking (Count 5). A jury trial on the superseding indictment was held from April 18 through 22, 2022. The jury found Appellant guilty of Counts 1 through 4 and not guilty of Count 5. The trial court sentenced Appellant to life in prison with the possibility of parole for Count 1 and to a consecutive five-year prison term for Count 4. Count 2 was vacated by operation of law, and Count 3 merged with Count 1 for sentencing purposes. Appellant timely filed a motion for new trial on May 5, 2022, and amended the motion through new counsel on March 29, 2024. Following a hearing on the motion for new trial on April 10, 2024, the trial court denied the motion on April 29, 2024. Appellant timely filed a notice of appeal. The case was docketed to this Court’s term beginning in December 2024 and was submitted for a decision on the briefs. 7-50.1. He also asserts a related claim of ineffective assistance of

trial counsel, arguing that trial counsel was deficient for failing to

timely file the plea in bar. As explained below, we affirm Appellant’s

convictions because our precedent forecloses his challenge to the

superior court’s jurisdiction, and he has failed to show prejudice

from trial counsel’s alleged ineffective assistance.

1. Appellant, who was 16 years old when the crimes occurred,

was arrested on December 21, 2018. On April 18, 2019 — 118 days

after Appellant’s arrest — a grand jury returned a true bill of

indictment charging Appellant with murder. And on February 25,

2020 — 431 days after Appellant’s arrest — a grand jury returned a

superseding true bill of indictment that likewise charged Appellant

with murder.

Shortly before trial, Appellant filed a plea in bar.2 Appellant

argued that the superior court lacked jurisdiction over the

superseding indictment because that indictment had not been

returned within the 180-day period prescribed by OCGA § 17-7-50.1,

2 As noted below, we need not decide whether the plea in bar was timely.

2 which provides in relevant part:

(a) Any child who is charged with a crime that is within the jurisdiction of the superior court . . . who is detained shall within 180 days of the date of detention be entitled to have the charge against him or her presented to the grand jury. The superior court shall, upon motion for an extension of time and after a hearing and good cause shown, grant one extension to the original 180 day period, not to exceed 90 additional days. (b) If the grand jury does not return a true bill against the detained child within the time limitations set forth in subsection (a) of this Code section, the detained child’s case shall be transferred to the juvenile court and shall proceed thereafter as provided in Chapter 11 of Title 15.

OCGA § 17-7-50.1 (a), (b). The trial court considered the plea in bar

on the merits and summarily denied it. Appellant was then tried on

the superseding indictment and found guilty of murder, among other

crimes.

In his motion for new trial, Appellant argued both that the trial

court had erred in denying his plea in bar and that trial counsel was

ineffective for failing to timely file the plea in bar. The superior court

rejected both claims. As to Appellant’s challenge to the court’s denial

of his plea in bar, the court concluded that, under the plain language

3 of OCGA § 17-7-50.1, the court had jurisdiction over Appellant’s case

because the original indictment charging Appellant with murder

was filed within the time limitation imposed by OCGA § 17-7-50.1,

and it was irrelevant that the case was reindicted after the 180-day

period. Turning to Appellant’s ineffective-assistance-of-counsel

claim, the court concluded in relevant part that Appellant had not

established prejudice because the trial court had considered

Appellant’s plea in bar on the merits rather than rejecting it as

untimely.

2. On appeal, Appellant argues again that the superior court

erred in denying his plea in bar because he was reindicted more than

180 days after his arrest, in violation of OCGA § 17-7-50.1, and the

court therefore lacked jurisdiction over his superseding indictment.

This argument, however, is foreclosed by our decision in State v.

Harris, 319 Ga. 665 (906 SE2d 402) (2024), which issued the day

after Appellant filed his principal brief in this Court. In Harris, we

held, based on the plain language of OCGA § 17-7-50.1, that the

“statute only requires that a true bill be returned on at least one

4 charge that is within the jurisdiction of the superior court [within

180 days of the date of the child’s detention] for the court to retain

jurisdiction.” Harris, 319 Ga. at 669. And we further held that “a

reindictment of that same defendant outside the 180 days” does not

“deprive[ ] the superior court of jurisdiction.” Id. at 670.

Here, it is undisputed that the grand jury returned the original

true bill of indictment within 180 days of Appellant’s arrest. And the

original indictment charged Appellant with malice murder, a

“charge that is within the jurisdiction of the superior court.” Harris,

319 Ga. at 669. See OCGA § 15-11-560 (b) (1) (“The superior court

shall have exclusive original jurisdiction over the trial of any child

13 to 17 years of age who is alleged to have committed . . .

[m]urder[.]”). Accordingly, the superior court “retain[ed]

jurisdiction” over the case, despite the fact that the grand jury

“reindict[ed]” Appellant more than 180 days after his arrest. Harris,

319 Ga. at 669-670. We therefore affirm the trial court’s denial of

Appellant’s plea in bar.

3. Appellant also argues on appeal that trial counsel was

5 ineffective for failing to file the plea in bar challenging the court’s

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Wilson v. State
591 S.E.2d 812 (Supreme Court of Georgia, 2004)
State v. Henry
864 S.E.2d 415 (Supreme Court of Georgia, 2021)
State v. Harris
906 S.E.2d 402 (Supreme Court of Georgia, 2024)
Zayas v. State
902 S.E.2d 583 (Supreme Court of Georgia, 2024)

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914 S.E.2d 800, 321 Ga. 349, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cooper-v-state-ga-2025.