Corvis Snellings v. State

CourtCourt of Appeals of Georgia
DecidedJune 6, 2024
DocketA24A0492
StatusPublished

This text of Corvis Snellings v. State (Corvis Snellings 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
Corvis Snellings v. State, (Ga. Ct. App. 2024).

Opinion

FOURTH DIVISION DILLARD, P. J., BROWN and PADGETT, 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

June 6, 2024

In the Court of Appeals of Georgia A24A0492. SNELLINGS v. THE STATE.

DILLARD, Presiding Judge.

In this interlocutory appeal, Corvis Snellings appeals from the trial court’s

denial of his motion to suppress evidence obtained during a traffic stop, contending

the stop was unconstitutionally prolonged and expanded beyond its initial

investigatory purpose. We agree and reverse.

When the facts material to a motion to suppress are disputed, it generally is for

the trial judge to “resolve those disputes and determine the material facts.”1 As a

result, we must generally accept the trial court’s findings unless they are clearly

1 Hughes v. State, 296 Ga. 744, 746 (1) (770 SE2d 636) (2015) (punctuation omitted). erroneous.2 And we are charged with construing the evidentiary record in the “light

most favorable to the factual findings and judgment of the trial court.”3 We must also

limit our consideration of disputed facts to those expressly found by the trial court.4

Nevertheless, when reviewing video evidence, we owe no deference to the trial

court’s findings of fact that are plainly discernable from the video and, thus,

undisputed.5 Finally, a trial court’s conclusion that “a traffic stop was [not]

unreasonably prolonged may often be a fact-intensive determination, but it is

2 Id. 3 Id. 4 Id. 5 See, e.g., Mack v. State, 296 Ga. 239, 241 (765 SE2d 896) (2014) (explaining that case involved no disputed facts because interrogation was captured on video recordings); Green v. State, 275 Ga. 569, 573 (2) n.11 (570 SE2d 207) (2002) (“In reviewing the videotaped exchange, we owe no deference to the trial court’s findings of fact, because it was not the subject of testimony requiring the trial court’s weighing of credibility or resolving of conflicts in the evidence.”); McNeil v. State, 362 Ga. App. 85, 85 (866 SE2d 249) (2021) (“An appellate court may, however, consider facts that definitively can be ascertained exclusively by reference to evidence that is uncontradicted and presents no questions of credibility, such as facts indisputably discernible from a videotape.” (punctuation omitted)); State v. Depol, 336 Ga. App. 191, 191 (784 SE2d 51) (2016) (explaining that “to the extent that the controlling facts are undisputed because they are plainly discernable from the patrol car-mounted video recording, as they are in this case, we review those facts de novo” (punctuation omitted)). 2 ultimately a holding of constitutional law that we review de novo.”6

So viewed, the record shows that on November 20, 2022, at 7:25 p.m., a deputy

with the Rockdale County Sheriff’s Department observed a vehicle driven by

Snellings as it traveled along I-20. The deputy noticed Snellings’s vehicle because it

swerved several times within its lane (touching the fog line), and because Snellings

briefly activated his right-turn signal even though there was no exit nearby. In light of

all this, the deputy initiated a traffic stop and approached Snellings from the passenger

side to investigate potential texting while driving or driving under the influence.

When the deputy made contact with Snellings, he grew increasingly concerned

about potential impairment because it took several requests before Snellings complied

and produced his proof of insurance. Then, after requesting his driver’s license,

Snellings handed over a piece of paper that was a DUI driver’s permit. The deputy

was unfamiliar with such a permit and needed to check to make sure it was valid. And

during this encounter, the deputy also detected a strong odor of something he could

not identify—perfume or alcohol—due to a recent bout with COVID-19.

And because his personal body radio was dying during the stop, the deputy was

forced to go back and forth between his car radio and Snellings’s vehicle, including to

6 State v. Allen, 298 Ga. 1, 4 (2) (779 SE2d 248) (2015); accord Weaver v. State, 357 Ga. App. 488, 488 (851 SE2d 125) (2020). 3 check the legitimacy of the DUI driver’s permit. After verifying Snellings’s license

and insurance information, the deputy was no longer investigating his failure to

maintain lane and told him that he was “not going to go any further with it.” Even so,

the deputy continued to engage with Snellings, asking questions to see whether he was

driving under the influence. The deputy also grew concerned that Snellings might be

having a health-related issue that mimicked intoxication. So, the deputy continued

questioning Snellings about the prior DUI, his driving on the night in question,

whether he had consumed an alcoholic beverage (which he denied), and, eventually,

whether he had any health-related issues that could have caused his erratic driving.

Snellings was on the phone with his wife throughout the stop, and immediately

after the deputy verified his information and indicated the investigation was over, he

told Snellings that he would allow him to leave his car behind and ride home with his

wife, who was en route to the scene. Nevertheless, the deputy insisted that Snellings

“be honest” with him and admit to having consumed an alcoholic beverage.

According to the deputy, he wanted to be sure Snellings was safe to continue driving

and told him that he would allow him to drive on his own if he passed a field-sobriety

test.

4 At the point when the deputy suggested field sobriety testing, four minutes had

passed since the deputy advised Snellings he was “not going to go any further with

[the investigation],” and Snellings had already indicated that he had health-related

issues (including high blood pressure). Snellings’s response to the suggestion, then,

was to refuse and say he felt ill. The deputy asked if Snellings needed medical

attention and wished to have an ambulance dispatched. And in response,

Snellings—whose wife by had not yet arrived on the scene—said that he would like

an ambulance.

The deputy returned to his vehicle and requested that an ambulance be

dispatched and that the Georgia State Patrol respond to the scene. And right after the

deputy requested the ambulance, but just before he requested that Georgia State Patrol

to respond, Snellings’s wife finally arrived.7 The deputy then walked over to her car

and advised that he would let Snellings go home with her if she could “talk some sense

into him” and get him to admit that he had been drinking, and that an ambulance and

Georgia State Patrol were en route. Snellings’s wife arrived approximately seven

minutes after the deputy told Snellings he could go home so long as his wife drove him

7 The trial court’s finding that Snellings’s wife arrived prior to the deputy summoning the ambulance is belied by both the body camera and dash-camera footage. But even if the trial court’s factual finding in this regard were supported by the record, it would not alter our ultimate conclusion. 5 and he admitted to drinking.

Thereafter, two Georgia State Patrol troopers arrived several minutes before the

ambulance; and upon their arrival, the deputy explained to one of the troopers why he

stopped Snellings, that he believed Snellings might have been texting and driving, that

there were signs of potential impairment, and that an ambulance was en route. But the

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Related

Green v. State
570 S.E.2d 207 (Supreme Court of Georgia, 2002)
Daniel v. State
597 S.E.2d 116 (Supreme Court of Georgia, 2004)
Migliore v. State
525 S.E.2d 166 (Court of Appeals of Georgia, 1999)
Powers v. State
582 S.E.2d 237 (Court of Appeals of Georgia, 2003)
State v. Long
689 S.E.2d 369 (Court of Appeals of Georgia, 2010)
Salmeron v. State
632 S.E.2d 645 (Supreme Court of Georgia, 2006)
Rodriguez v. State
761 S.E.2d 19 (Supreme Court of Georgia, 2014)
Mack v. State
765 S.E.2d 896 (Supreme Court of Georgia, 2014)
Hughes v. State
770 S.E.2d 636 (Supreme Court of Georgia, 2015)
State v. Allen
779 S.E.2d 248 (Supreme Court of Georgia, 2015)
The State v. Depol
784 S.E.2d 51 (Court of Appeals of Georgia, 2016)
ALLEN v. the STATE.
824 S.E.2d 50 (Court of Appeals of Georgia, 2019)
Crawford-Thomas v. State
597 S.E.2d 635 (Court of Appeals of Georgia, 2004)
Coghlan v. State
737 S.E.2d 332 (Court of Appeals of Georgia, 2013)
Bryant v. State
756 S.E.2d 621 (Court of Appeals of Georgia, 2014)

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Bluebook (online)
Corvis Snellings v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/corvis-snellings-v-state-gactapp-2024.