Crowder v. State of Georgia

844 S.E.2d 806, 309 Ga. 66
CourtSupreme Court of Georgia
DecidedJune 16, 2020
DocketS19G0931
StatusPublished
Cited by15 cases

This text of 844 S.E.2d 806 (Crowder v. State of Georgia) 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
Crowder v. State of Georgia, 844 S.E.2d 806, 309 Ga. 66 (Ga. 2020).

Opinion

309 Ga. 66 FINAL COPY

S19G0931. CROWDER v. STATE OF GEORGIA.

WARREN, Justice.

This case stems from an October 2016 incident at the Atlanta

airport during which law enforcement officers seized $46,820 in cash

from Shara Cumins, James Crowder’s daughter. In the ensuing in

rem forfeiture proceeding under OCGA § 9-16-12, the trial court

awarded Crowder the property. The Court of Appeals, however,

reversed. See Crowder v. State of Ga., 348 Ga. App. 850 (823 SE2d

384) (2019). We granted certiorari to consider two questions:

In an in rem forfeiture proceeding, may the forfeiture complaint be served by publication in the first instance when an interest holder resides out of state?

Must a trial court rule on a pending motion for more definite statement before striking a claimant’s answer as insufficient?

As to the first question, we conclude that the Court of Appeals

properly interpreted OCGA § 9-16-12 (b) (3) as permitting service by

publication in an in rem forfeiture proceeding if the owner of the subject property resides outside of Georgia, and properly rejected

Crowder’s claims that personal service was required and that the

State’s complaint should have been dismissed based on its failure to

personally serve him. Nevertheless, and as explained more below,

the Court of Appeals must remand the case to the trial court for it

to address Crowder’s claim that the State’s service by publication

did not satisfy due process. As for the second question, we conclude

that OCGA § 9-16-12 (c) (2) requires a trial court to first rule on a

motion for a more definite statement before dismissing a claimant’s

answer. Because the Court of Appeals implicitly answered this

question in the negative, we reverse this portion of the Court of

Appeals’s judgment.

1. Background.

(a) The facts of the case are accurately recounted in the Court

of Appeals’s opinion and some of the key facts are recounted below.

See Crowder, 348 Ga. App. at 850-853. After law enforcement

officers seized $46,820 in cash from Cumins, the State filed an in

rem complaint for forfeiture against the property in December 2016 and named Cumins as a potential owner of the property. See OCGA

§ 9-16-12 (a); § 9-16-12 (b) (1). Cumins, however, maintained that

the cash that had been seized from her at the airport belonged to

Crowder, and she was later dismissed from the case. In February

2017, the State amended its forfeiture complaint, naming Crowder,

who was a resident of Alabama, as a potential owner. The State

attempted to personally serve Crowder but was unsuccessful.

Thereafter, in April 2017, the State obtained an order for service by

publication under OCGA § 9-16-12 (b) (3), which provides that, if an

“owner or interest holder is unknown or resides out of this state . . .

a copy of the notice of the complaint for forfeiture shall be published

once a week for two consecutive weeks in the legal organ of the

county in which the complaint for forfeiture is pending.”1 Under

1 OCGA § 9-16-12 (b) (3) provides in full:

If real property is the subject of the complaint for forfeiture or the owner or interest holder is unknown or resides out of this state or departs this state or cannot after due diligence be found within this state or conceals himself or herself so as to avoid service, a copy of the notice of the complaint for forfeiture shall be published once a week for two consecutive weeks in the legal organ of the county in which the complaint for forfeiture is pending. Such publication shall be deemed notice to any and all persons having OCGA § 9-16-12 (c) (1), Crowder had 30 days from the “date of final

publication” on April 26, 2017, to file an answer, but he did not file

one until December 29, 2017.

Meanwhile, on December 6, 2017, in a pleading styled a

“motion for judgment on the pleadings,” the State contended that

Crowder had failed to answer the complaint within 30 days of the

date of final service by publication and that it was therefore entitled

to default judgment under OCGA § 9-16-12 (e) and OCGA § 9-11-55.2

On December 29, Crowder filed an unverified answer, admitting

that he was the owner of the property but contending that he had

not been properly served with the State’s forfeiture complaint. On

January 4, 2018, the State filed a motion for a more definite

an interest in or right affected by such complaint for forfeiture and from any sale of the property resulting therefrom, but shall not constitute notice to an interest holder unless that person is unknown or resides out of this state or departs this state or cannot after due diligence be found within this state or conceals himself or herself to avoid service.

2 OCGA § 9-16-12 (e) provides that “[i]f at the expiration of the period set

forth in subsection (c) of this Code section no answer has been filed, the state attorney may seek a default judgment as provided in Code Section 9-11-55[.]” statement under OCGA § 9-16-12 (c) (2), contending that Crowder’s

answer failed to meet the requirements of OCGA § 9-16-12 (c) (1).3

In its motion for a more definite statement, the State did not move

to dismiss Crowder’s answer for failure to comply with the

requirements of paragraph (c) (1).

On January 9, 2018, Crowder moved to dismiss the State’s

complaint on the ground that the State had not personally served

him, as he claimed was required by OCGA § 9-16-12 (b) (2), and that,

even if service by publication were permitted, it did not comport with

due process principles under the circumstances of this case.

At a hearing in January 2018, Crowder testified that the cash

that had been seized belonged to him; that he received it in lump

3 Paragraph (c) (1) of OCGA § 9-16-12 provides that “[a]n answer shall

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Bluebook (online)
844 S.E.2d 806, 309 Ga. 66, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crowder-v-state-of-georgia-ga-2020.