Dugar v. State

877 S.E.2d 213, 314 Ga. 376
CourtSupreme Court of Georgia
DecidedAugust 9, 2022
DocketS22A0707
StatusPublished
Cited by5 cases

This text of 877 S.E.2d 213 (Dugar 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
Dugar v. State, 877 S.E.2d 213, 314 Ga. 376 (Ga. 2022).

Opinion

314 Ga. 376 FINAL COPY

S22A0707. DUGAR v. THE STATE.

BOGGS, Chief Justice.

In 2017, Rita Mary Dugar shot and killed Jon Trevor Townley

at the home of Dugar’s ex-boyfriend, Juandrago Carter, in

Covington. Dugar called 911 and was arrested at the scene.

According to Dugar, she accidentally shot Townley while attempting

to fire a warning shot during a melee involving Townley, Carter, and

two other individuals, Shane Dobbs and Sarah Smith. At a 2021

bench trial, the court convicted Dugar of felony murder, aggravated

assault, and a firearm-possession offense. She appeals, asserting

four enumerations of error, all related to her waiver of a jury trial.1

1 The crimes occurred on February 28, 2017. On May 5, 2017, a Newton

County grand jury indicted Dugar for malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. At a bench trial from February 23 to 24, 2021, the court found Dugar not guilty of malice murder but guilty of the remaining counts. The trial court sentenced Dugar to imprisonment for life for felony murder and to a consecutive term of five years on probation for the firearm-possession conviction; the court merged the aggravated assault charge into the felony Dugar contends that: (1) the original trial judge made remarks

at a bond hearing that unduly influenced her decision to waive her

right to a jury trial and, citing OCGA § 17-8-57, contends that the

trial judge improperly commented on the merits of her case; (2) the

State failed to show that her waiver of a jury trial was knowing,

voluntary, and intelligent; (3) her trial counsel was ineffective for

failing to advise her of her right to revoke her waiver of a jury trial

after the case was reassigned to a new judge; and (4) counsel’s

actions denied her the right to revoke her waiver of a jury trial. For

the reasons that follow, we affirm.2

1. Dugar first asserts that the original trial judge’s remarks

murder conviction. Dugar filed a timely motion for new trial, which she amended with new counsel on June 25, 2021. After a hearing on August 12, 2021, the trial court denied the motion on December 29, 2021. Dugar filed a timely notice of appeal directed to the Court of Appeals, which properly transferred the case to this Court on February 10, 2022. The case was docketed in this Court to the April 2022 term and submitted for a decision on the briefs. 2 As Dugar does not challenge the sufficiency of the evidence to support

her convictions, we note only those portions of the record necessary to address her claims of error. We no longer routinely review evidentiary sufficiency sua sponte, except with respect to murder convictions resulting in the death penalty. See Davenport v. State, 309 Ga. 385, 398-399 (4) (b) (846 SE2d 83) (2020).

2 during an initial bond hearing unduly influenced her to waive her

right to a jury trial, rendering the waiver involuntary. This claim is

meritless.

(a) Two months after the shooting and before Dugar was

indicted, the original trial judge presided over a bond hearing. The

prosecutor summarized the facts of the case and asked that the court

deny bond because Dugar was “facing . . . possibly being charged

with malice murder and felony murder” and had attempted to

contact Carter multiple times from the jail about his statement to

police. The judge stated that he was less concerned about the risk of

flight than the possibility of witness intimidation or collusion, and

the public defender, who was representing Dugar at the time, said

that Dugar was willing to have no contact with the witnesses to the

shooting. The judge then had the following exchange with counsel

for the parties:

COURT: Because nobody else was charged, which I’m not sure how you all do that and I don’t know enough about it. This murder happened — well, this incident occurred, the death occurred we shall say in February . . . . Less than 60 days ago.

3 DEFENSE COUNSEL: She’s been in custody since the time, which was . . . February 28th, and she is willing to remain away from any of those individuals. Judge, just to give you a little bit more insight as to the kind of the relation of these folks, Ms. Dugar was only there with the other individuals, she was not part of the actual argument, and [the prosecutor] is correct that she did cooperate with police, did let them know that she was the one that — COURT: Well, she made the call apparently. You said 911 call; right? DEFENSE COUNSEL: She did call 911. COURT: Which is not the usual in the situation of an alleged murderer. DEFENSE COUNSEL: That’s correct. COURT: So I heard all of that. DEFENSE COUNSEL: She did . . . remain on the scene to talk to police and did admit that she was trying to fire a warning shot to try to break up the argument. COURT: I know. This is what we’re going to do. All right. I’m not going . . . to grant a bond today and rather than there being a denial of record I’ll withhold ruling thereon. I hope, [prosecutor], you all are going to look at this as you mentioned felony murder and malice murder you may look at it the other way. . . . This is something that might be better viewed as manslaughter . . . based on the snippet that I’ve gotten involved and she made the call. All right. So I’m saying as you all review it, you know . . . don’t scan it, but do that as well. Let’s withhold my ruling on the bond. Okay. Give you all a chance to flesh out more facts. Because I’m with you, I don’t know how people go to a fight and the only one that gets . . . arrested is her. And especially talking about felony murder. . . . And underlying certainly I presume was the robbery or whatever — the theft that they were seeking —

4 STATE: Aggravated assault, Your Honor. COURT: All right. So in any event, you all flesh it out. That’s what you all get paid the big bucks for.

At a second bond hearing a month later, after Dugar had been

indicted, the attorneys reminded the original trial judge of his

earlier statement at the first bond hearing, and the prosecutor

provided more information to the court, including further details of

Dugar’s recorded calls from the jail to Carter. The judge denied

Dugar bond:

COURT: It’s kind of hard to swallow that. . . . She made a call on the day of the prelim to a witness she had just heard in court. . . . That’s not what innocent folks do. And then to say on the call that we have to get our story straight to better help me to do that. Now, you can take that and you can spin it anyway you want to, but there’s not any[ ]way I can spin it. Bond denied. We’ll let it fall where it may. File your speedy [trial motion] and we’ll get a trial. I’ve got speedies in the record so we’ll find out where they are. So bond denied.

Attempting to clarify the basis for the bond ruling, the prosecutor

asked, “[T]he bond is denied for intimidating and influencing

witnesses?” The judge replied, “And for a risk to the community, you

can note both.”

5 Later the same month, new counsel filed an entry of

appearance on behalf of Dugar, and six months later filed a motion

for dismissal under the immunity statute, OCGA § 16-3-24.2, on the

basis of justification by self-defense. The original trial judge

presided over an evidentiary hearing in April 2018, at which Dugar,

Carter, Smith, a sheriff’s deputy, and a Social Circle police officer all

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Cite This Page — Counsel Stack

Bluebook (online)
877 S.E.2d 213, 314 Ga. 376, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dugar-v-state-ga-2022.