Edward Pitt v. State

CourtCourt of Appeals of Georgia
DecidedJune 15, 2016
DocketA16A0408
StatusPublished

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Bluebook
Edward Pitt v. State, (Ga. Ct. App. 2016).

Opinion

SECOND DIVISION BARNES, P. J., BOGGS and RICKMAN, 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. http://www.gaappeals.us/rules

June 15, 2016

In the Court of Appeals of Georgia A16A0408. PITT v. THE STATE.

BARNES, Presiding Judge.

A jury convicted Edward Pitt of two counts of child molestation and one count

of aggravated child molestation, and the trial court sentenced him to 35 years to serve,

followed by life on probation. Following the denial of his motion for new trial, Pitt

appeals, contending that he was absent during a critical phase of his trial in violation

of his constitutional rights to due process and a fair trial and is therefore entitled to

a new trial. For the reasons that follow, we affirm.

Pitt was indicted for aggravated child molestation for placing his mouth on the

sex organ of the underage victim, for child molestation for rubbing his penis on the

victim’s vaginal area, and for child molestation for touching the victim with his hand

on her inner thigh, buttocks, and vaginal area.1 Pitt had dated the victim’s mother and

lived for a time with the victim, her mother, and her brother. The victim, who was 11

1 Pitt was acquitted of a second count of aggravated child molestation. as of trial, testified that when she was 8 or 9, Pitt had called her into her mother’s

bedroom, placed his hands and mouth on her “private area,” pushed his private area

into hers, and would not let her leave the room until she said aloud that nothing had

happened between them. The victim testified that these incidents happened between

10 to 15 times, and she did not tell her mother about them because she was scared Pitt

would hurt her or her mother. After Pitt moved out, the victim said, she had “done her

best to forget everything about him,” but then heard his name during a conversation

and made an outcry.

During the victim’s subsequent therapy sessions, she mentioned a conversation

she had had with another girl whose mother had also previously dated Pitt, and that

other girl became a similar transaction witness in this case.2 That witness testified that

when she was 9 or 10, Pitt followed her into her bedroom when she went to change

clothes and said he would take her for ice cream if she showed him her private parts.

He flashed his penis at her, and she flashed back “really quick so he would get out of

[her] room.” Then she changed clothes and they went for ice cream.

2 This case was tried in 2012, before the effective date of the new evidence code.

2 While Pitt does not challenge the sufficiency of the evidence against him, our

review of the record establishes that the evidence presented to the jury was sufficient

for a rational jury to determine that Pitt was guilty beyond a reasonable doubt of the

offenses for which he was convicted. See Harris v. State, 333 Ga. App. 118, 119 (1)

(a) (775 SE2d 602) (2015).

Pitt contends that he was denied his Georgia constitutional right to be present

during all critical stages of his trial because he was absent during what he

characterizes as the trial court’s “demand for an offer of proof as to the relevance of

certain defense evidence.”

“Within the Georgia constitutional right to the courts[3] is a criminal

defendant’s right to be present, and see and hear, all the proceedings which are had

against him on the trial before the Court.” (Citations and punctuation omitted.)

Hanifa v. State, 269 Ga. 797, 807 (6) (505 SE2d 731) (1998).

The right to be present attaches at any stage of a criminal proceeding that is critical to its outcome if the defendant’s presence would contribute to the fairness of the procedure. This Court has determined that a critical stage in a criminal prosecution is one in which a

3 Art. I, Sec. I, Par. XII of the Georgia Constitution provides: “No person shall be deprived of the right to prosecute or defend, either in person or by an attorney, that person’s own cause in any of the courts of this state.”

3 defendant’s rights may be lost, defenses waived, privileges claimed or waived, or one in which the outcome of the case is substantially affected in some other way.

(Citation and punctuation omitted.) Huff v. State, 274 Ga. 110, 111 (2) (549 SE2d

370) (2001).

While denial of the corresponding federal constitutional right to be present is

subject to harmless error review on appeal, a denial of the right to be present

guaranteed by the Georgia Constitution is presumed to be prejudicial unless the

defendant waived his right or later acquiesced to proceedings conducted in his

absence. Peterson v. State, 284 Ga. 275, 278-279 (663 SE2d 164) (2008); Holsey v.

State, 271 Ga. 856, 860-861 (5) (524 SE2d 473) (1999).

The six-day trial in this case began on a Monday. The State introduced 12

witnesses, including the victim, her mother, the similar transaction witness and her

mother, two inmates who testified regarding disclosures Pitt made to them, law

enforcement personnel, and experts in the area of child molestation, most of whom

had interacted directly with the victim. The State completed its presentation of

evidence at the end of the day on Wednesday and rested before the jury Thursday

morning.

4 The defense then called a former cell mate of Pitt’s, who testified that in jail,

no one would have admitted to having child molestation charges against him. The

next witness was a probation officer who had been overseeing Pitt’s probation after

he pled guilty to a domestic violence misdemeanor against the victim’s mother. The

defense then recalled the victim’s forensic interviewer for cross-examination and

played a DVD recording of the entire interview with the victim. The plan was to play

the interviews with the victim and the similar transaction witness back-to-back, to

highlight discrepancies, but technical difficulties arose with the courtroom’s speaker

system and the audio dropped out several times while the defense played the

recording of the victim’s interview. The parties unsuccessfully attempted to fix the

audio problem during the lunch break, and the State provided the defense with a copy

of a transcript of the interview.

After lunch, Pitt cross-examined the interviewer to fill in the gaps where the

audio of the victim’s forensic interview had dropped out. Pitt then played the similar

transaction witness’s forensic interview, which was easier to follow despite the

continued audio problems because the State had provided copies of that transcript for

the jurors in addition to the defense.

5 Over objection, Pitt then began to play a DVD recording of the State’s

interview with the first of the two inmates who testified against Pitt, which Pitt had

successfully tendered into evidence the previous day during the interrogating

detective’s testimony. The sound still was not working properly, and the recording

was paused while the parties tried a different hardware configuration, but the problem

continued and the recording was paused again. Hoping to resolve the technical

difficulties that evening after the jury was excused, Pitt shuffled his planned order of

witnesses so he could continue presenting his case. A records custodian from the jail

identified visitor sign-in sheets and a log book in which deputies recorded daily

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Related

Peterson v. State
663 S.E.2d 164 (Supreme Court of Georgia, 2008)
Holsey v. State
524 S.E.2d 473 (Supreme Court of Georgia, 1999)
Huff v. State
549 S.E.2d 370 (Supreme Court of Georgia, 2001)
Hanifa v. State
505 S.E.2d 731 (Supreme Court of Georgia, 1998)
Harris v. the State
775 S.E.2d 602 (Court of Appeals of Georgia, 2015)
Tolbert v. State
742 S.E.2d 152 (Court of Appeals of Georgia, 2013)

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Bluebook (online)
Edward Pitt v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edward-pitt-v-state-gactapp-2016.