Diego Ramos-Garcia v. State

CourtCourt of Appeals of Georgia
DecidedMay 12, 2026
DocketA26A0394
StatusPublished

This text of Diego Ramos-Garcia v. State (Diego Ramos-Garcia 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
Diego Ramos-Garcia v. State, (Ga. Ct. App. 2026).

Opinion

SECOND DIVISION DOYLE, P. J., DAVIS, J., and SENIOR JUDGE FULLER

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

May 12, 2026

In the Court of Appeals of Georgia A26A0394. RAMOS-GARCIA v. THE STATE.

DAVIS, Judge.

A Cherokee County jury found Diego Ramos-Garcia guilty of false

imprisonment, aggravated stalking, and battery, family violence. Ramos-Garcia

appeals from the trial court’s order denying his motion for new trial, arguing that (1)

the evidence was insufficient to sustain his convictions; and (2) the trial court erred

by refusing his request for a jury instruction for the aggravated stalking offense. For

the reasons that follow, we conclude that the evidence was sufficient to sustain

Ramos-Garcia’s convictions. We conclude, however, that the trial court erred by

denying Ramos-Garcia’s request for a jury instruction for the aggravated stalking

offense and that the error was harmful. We therefore affirm Ramos-Garcia’s convictions for false imprisonment and battery, family violence, but we reverse his

conviction for aggravated stalking, and we remand the case for a new trial on that

charge.

Viewed in the light most favorable to the verdicts,1 the evidence presented at

trial shows the following. Ramos-Garcia previously lived with Maria Mendez Juarez

and her four children on Academy Street in Canton, Georgia. Juarez and Ramos-

Garcia met through a Facebook page, and he subsequently rented a room in her

house.2 According to Juarez, she and Ramos-Garcia were “like family,” but she was

not romantically involved with him. In April 2021, Juarez and Ramos-Garcia got into

an altercation, which resulted in Juarez sustaining a bruise to her arm.3 Following that

incident, Ramos-Garcia was arrested, and as part of the special conditions of his bond,

he was prohibited from approaching or communicating with Juarez, and he was

1 Jackson v. Virginia, 443 U. S. 307 (99 SCt 2781, 61 LE2d 560) (1979). 2 Juarez testified that Ramos-Garcia was not living with her at the time of trial. 3 Juarez denied that Ramos-Garcia hit her, and she testified that the bruise was caused by her hitting a door or a bed. 2 ordered to stay away from her and her home on Academy Street. Ramos-Garcia signed

a form acknowledging the special conditions of his pre-trial release.4

In the evening hours of February 12, 2022, Juarez’s cousin called 911, and

Juarez exclaimed to the 911 operator, “he’s hitting me, he’s hitting me,” and the 911

translator noted that he heard a male voice in the background and that it sounded like

a scuffle had ensued.5 Juarez gave the operator her home address on Academy Street,

and she said, “he’s following me.” Officer Michael Caplan of the Canton Police

Department responded to Juarez’s home, but she was not there. Dispatch traced the

location of Juarez’s call, and Officer Caplan ultimately found Juarez outside of a bar

that was located near her home. Officer Caplan said that Juarez appeared

“distressed,” and he noted that a man, whom he later identified as Ramos-Garcia, was

standing near Juarez and that the man attempted to leave as he approached. Rodney

Starks, a security guard for the establishment, “aggressively” pointed at Ramos-

Garcia, and Officer Caplan detained him. Starks said that he saw Juarez on the ground

in the parking lot and that Ramos-Garcia held her by her hair and dragged her and hit

4 The special conditions of bond form was entered into evidence. 5 The 911 call was entered into evidence and played for the jury. 3 her while she screamed for help, and it appeared that Ramos-Garcia was trying to get

Juarez into his vehicle against her will.

Officer Caplan then spoke with Juarez and asked her who Ramos-Garcia was,

and she said that he was her “novio,” which Officer Caplan interpreted as

“boyfriend,” and she stated that Ramos-Garcia “mistreats” her. Juarez also told

Officer Caplan that Ramos-Garcia lived with her on Academy Street, and while

speaking with Juarez, Officer Caplan observed “a large knot on the back of her head.”

At trial, Juarez testified that Ramos-Garcia only grabbed her hand and that she

accidentally fell and hit her head. She also denied that Ramos-Garcia hit or punched

her.

Ramos-Garcia was indicted on criminal attempt to commit kidnapping with

bodily injury (OCGA § 16-4-1), false imprisonment (OCGA § 16-5-41), aggravated

stalking (OCGA § 16-5-91), and battery, family violence (OCGA § 16-5-23.1(a) and

(f)). Before trial, Ramos-Garcia submitted a written request to charge the jury on the

definition of “harassing and intimidating” for the aggravated stalking charge, but the

trial court denied his request. After the trial, the jury found Ramos-Garcia guilty of

false imprisonment, aggravated stalking, and battery, family violence, but it acquitted

4 him of criminal attempt to commit kidnapping with bodily injury. The trial court

imposed a 10-year sentence, with the first 3 years to be served in confinement and the

balance to be served on probation.6 Ramos-Garcia filed a motion for new trial, which

the trial court denied after a hearing. This appeal followed.

1. First, in related enumerations of error, Ramos-Garcia argues that the

evidence was insufficient to sustain his convictions. Specifically, he argues that (1)

there was no evidence that he detained or confined Juarez to sustain his false

imprisonment conviction; (2) he only committed a single violation of the protective

order, which was insufficient to show a pattern of harassing and intimidating behavior

to sustain his aggravated stalking conviction; and (3) there was no evidence that he

was a “household member” to sustain his conviction for battery, family violence. We

disagree and conclude that the evidence was sufficient to sustain his convictions.

On appeal from a criminal conviction, we view the evidence in the light most favorable to support the jury’s verdict, and the defendant no longer enjoys a presumption of innocence; moreover, this Court determines evidence sufficiency and does not weigh the evidence or determine witness credibility. Resolving evidentiary conflicts and inconsistencies, and assessing witness credibility, are the province of the factfinder, not

6 The trial court also imposed a $1,000 fine. 5 this Court. As long as there is some evidence, even though contradicted, to support each necessary element of the state’s case, this Court will uphold the jury’s verdict.

Johnson v. State, 367 Ga. App. 344 (886 SE2d 5) (2023). We note that

[t]his is true even in cases in which the victim recants her previous accusation against the defendant. The reason for this rule is that a victim’s prior inconsistent statements are admissible as substantive evidence for the jury’s consideration. Thus, a jury is authorized to believe the victim’s pre-trial statements rather than her in-court disavowal.

McCurdy v. State, 359 Ga. App.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Gillespie v. State
633 S.E.2d 632 (Court of Appeals of Georgia, 2006)
Pierce v. State
687 S.E.2d 185 (Court of Appeals of Georgia, 2009)
Rehberger v. State
510 S.E.2d 594 (Court of Appeals of Georgia, 1998)
Hollis v. State
672 S.E.2d 487 (Court of Appeals of Georgia, 2009)
State v. Burke
695 S.E.2d 649 (Supreme Court of Georgia, 2010)
Moore v. the State
796 S.E.2d 754 (Court of Appeals of Georgia, 2017)
SALAZAR-BALDERAS v. the STATE.
806 S.E.2d 644 (Court of Appeals of Georgia, 2017)
Kiser v. State
755 S.E.2d 505 (Court of Appeals of Georgia, 2014)
Slaughter v. State
760 S.E.2d 609 (Court of Appeals of Georgia, 2014)
Weyer v. State
776 S.E.2d 304 (Court of Appeals of Georgia, 2015)
Beck v. State
852 S.E.2d 535 (Supreme Court of Georgia, 2020)
Burley v. State
888 S.E.2d 507 (Supreme Court of Georgia, 2023)
Clark v. State
883 S.E.2d 317 (Supreme Court of Georgia, 2023)
CAMPBELL v. THE STATE (Four Cases)
907 S.E.2d 871 (Supreme Court of Georgia, 2024)

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Diego Ramos-Garcia v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/diego-ramos-garcia-v-state-gactapp-2026.