Craft v. State

618 S.E.2d 104, 274 Ga. App. 410, 2005 Fulton County D. Rep. 2393, 2005 Ga. App. LEXIS 778
CourtCourt of Appeals of Georgia
DecidedJuly 14, 2005
DocketA05A0010
StatusPublished
Cited by9 cases

This text of 618 S.E.2d 104 (Craft 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
Craft v. State, 618 S.E.2d 104, 274 Ga. App. 410, 2005 Fulton County D. Rep. 2393, 2005 Ga. App. LEXIS 778 (Ga. Ct. App. 2005).

Opinions

Phipps, Judge.

Rodney Craft was tried by a jury and convicted of two counts of child molestation. He was sentenced to forty years, ten in confinement and thirty on probation. On appeal, he claims that the trial court erred in its questioning of two witnesses and in refusing to allow his trial counsel to introduce evidence of the victims’ academic records. Craft also charges his trial counsel with ineffective assistance. We conclude that the trial court violated OCGA § 17-8-57 by its questioning of one witness. We further conclude that the statutory violation, coupled with the trial court’s failure to allow Craft a thorough and sifting cross-examination, constituted plain error. Therefore, we reverse. Because the evidence was sufficient to support the verdict under the standard of Jackson v. Virginia,1 the case can be retried.2

The evidence showed that C. W. and T. J., both 15 years old, were walking to school in Columbus on August 26, 2002. As they walked by Craft’s house, Craft said to C. W, “Hey, look over here.” C. W. looked in that direction and saw Craft standing naked at his door, masturbating. C. W. told T. J. to look, and T. J. also saw Craft naked and masturbating. They ran the rest of the way to school and reported the incident to the assistant principal, Senobia Moore. After investigation by Columbus police officers, Craft was arrested.

1. Craft claims that the trial court erred by asking Moore questions about the character of the victims in such a manner as to [411]*411cause the jury to believe that the court had formed or expressed an opinion about the veracity of the victims, in violation of OCGA § 17-8-57.

The following exchange is at issue:

THE COURT: Ms. Moore, I just have a couple of questions for you. Do you know what kind of students these two girls are? THE WITNESS: Yes. They are very good students. Actually, one is a cheerleader3 and they are very mannerable, very poli[t]e young ladies. And, again, knowing that they are not ones that are real wild and real, you know, loud in the halls and everything, the way that I saw them that day, you know, caused my attention to go to them.
THE COURT: Are the cheerleaders at [your school] required to make a certain grade-point average?
THE WITNESS: Yes, well, we follow the State, the code that goes with athletes, and if you —
THE COURT: So that’s the same requirement?
THE WITNESS: Yes, it is. And if you fail two classes, you cannot participate. So it’s the fail-no-participate rule. However, our students are still monitored. All of our athletes are monitored; and if their grades begin to fall low, they can be pulled from a game or pulled from participating for a period of time.
THE COURT: Based on the individual school policy?
THE WITNESS: Yes.

Craft did not object to the court’s questioning during trial and has therefore waived his right to pursue the issue on appeal.4 Despite counsel’s failure to preserve this issue, we must consider whether the trial court’s actions violated OCGA § 17-8-57 and, if so, whether that violation constituted plain error.5

“It is error for any judge in any criminal case, during its progress or in his charge to the jury, to express or intimate his opinion as to what has or has not been proved or as to the guilt of the accused.”6 The purpose of this limitation at least in part is to prevent the jury from being influenced by any disclosure of the judge’s opinion regarding a witness’s credibility.7

[412]*412“The credibility and standing of the witness is an issuable fact in every case — a most material fact. Therefore, anything which tends to uphold, to support, to disparage, or to lower the character and the resulting credibility of the witness is vitally connected with the facts of the case.”8 This case was based almost entirely on the testimony of the victims. As a result, their credibility was the most important issue in the case.

The testimony elicited by the trial court bolstered the credibility of the victims, which had not previously been challenged. By its actions, the court stepped over the line between developing the truth of the case and intimating its opinion on an issue that was in the sole province of the jury, thereby violating OCGA § 17-8-57.9

Focused on what it calls the court’s “leeway” in posing questions during a criminal trial, the dissent misses the point. We do not challenge the trial court’s right to “occasional and cautious” questioning of witnesses to develop the truth of a case. Instead, we hold that the specific questioning in this case constituted a violation of OCGA § 17-8-57. Contrary to the dissent’s argument, we are not breaking new ground or establishing a new rule in holding that a trial court violates OCGA § 17-8-57 when it intimates its opinion as to the credibility of a witness — an issue within the sole province of the jury.10 We are merely applying existing case law to the specific facts of this case — a task performed daily by judges at the trial and appellate levels.

We do not conclude that the trial court’s improper questioning, standing alone, constituted plain error. Instead, we consider the issue of plain error in connection with Craft’s next claim.

2. After the court asked Moore questions about the victims’ school performance, Craft sought to question her about their academic history and disciplinary history. Craft asked Moore what kind of student C. W. was, Moore admitted that even polite students get into minor trouble and, at Craft’s request, Moore explained “administrative detention.” The state objected to the line of questioning at that point. Craft’s counsel responded that he had documents that contradicted some of Moore’s testimony about the victims’ school performance and conduct. The court refused to allow Craft to pursue the matter further, stating “you’re not going to make these victims look bad.” Although this statement was made during a bench conference, [413]*413it demonstrated that the trial court had reached the conclusion that the state had already proven that the girls were victims. Further, that conclusion likely formed the basis for the trial court’s decision to shut down Craft’s cross-examination. Craft claims that the trial court’s refusal to allow further cross-examination constituted an abuse of the court’s discretion.

As noted previously, the testimony elicited by the trial court bolstered the credibility of the victims, which had not previously been challenged.

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Craft v. State
618 S.E.2d 104 (Court of Appeals of Georgia, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
618 S.E.2d 104, 274 Ga. App. 410, 2005 Fulton County D. Rep. 2393, 2005 Ga. App. LEXIS 778, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craft-v-state-gactapp-2005.