GARRETT SMITH v. STATE OF GEORGIA

CourtCourt of Appeals of Georgia
DecidedFebruary 28, 2025
DocketA22A1455
StatusPublished

This text of GARRETT SMITH v. STATE OF GEORGIA (GARRETT SMITH v. STATE OF GEORGIA) 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
GARRETT SMITH v. STATE OF GEORGIA, (Ga. Ct. App. 2025).

Opinion

SECOND DIVISION RICKMAN, P. J., PIPKIN and DAVIS, 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. https://www.gaappeals.us/rules

February 28, 2025

In the Court of Appeals of Georgia A22A1455. SMITH et al. v. STATE OF GEORGIA.

RICKMAN, Presiding Judge.

This appeal from an in rem civil-asset-forfeiture proceeding is before us on

remand from the Supreme Court of Georgia. In Smith v. State of Ga., 366 Ga. App.

815, 820 (884 SE2d 403) (2023) (“Smith I”), we granted the application for

interlocutory appeal filed by Garrett Smith, Stacey Smith, SmithCo Recycling, LLC,

and SmithCo Transfer, LLC, (“Appellants”) and affirmed the trial court’s order

denying in part Appellants’ motion to dismiss the State’s amended complaint for

forfeiture, their motion to strike the State’s second amended complaint, their motion

to dismiss the State’s second amended complaint, and their motion for release of

property. Our Supreme Court granted certiorari to consider (1) “whether [this Court] erred in holding that OCGA § 9-16-12 (f)’s 60-day time period for holding a bench

trial or continuing the trial for good cause in an in rem civil-asset-forfeiture case began

to run when the last claimant, who was never served, filed an answer without raising

the defense of insufficient service”; (2) “if [this Court] erred in holding that the

intent element of theft by taking could be inferred from the allegations of the second

amended complaint, and thus that the second amended complaint satisfied OCGA §

9-16-12 (a)’s requirement that the complaint allege the essential elements of the

offense”; and (3) “if the second amended complaint alleged the essential elements of

at least one criminal violation, assuming that it did not adequately allege the essential

elements of theft by taking.”Smith v. State of Ga., 319 Ga. 352, 352-353 (903 SE2d

878) (2024) (“Smith II”).

The Supreme Court vacated Division 3 of our decision, without expressing any

opinion as to whether this Court correctly interpreted OCGA § 9-16-12 (f), and

concluded that “Appellants are estopped from arguing that the trial court or [this

Court] erred in equating the date that SmithCo Transfer answered the complaint with

the date that SmithCo Transfer was served.” Smith II, 319 Ga. at 360 (2). The

Supreme Court also concluded that “the second amended complaint failed to

2 adequately allege theft by taking” and reversed this Court’s conclusion to the

contrary. Id. at 366 (3) (b). The Supreme Court noted that neither the trial court nor

this Court addressed whether the second amended complaint adequately alleged the

essential elements of any criminal offense other than theft by taking, declined to make

such a determination itself, and remanded for further proceedings consistent with its

opinion. Id. at 367 (4). Accordingly, we vacate Divisions 2 and 3 of our opinion, adopt

the Supreme Court’s opinion as our own with respect to those divisions, and address

whether the second amended complaint adequately alleged the essential elements of

any criminal offense other than theft by taking. Division 1 of our opinion was not

affected by the Supreme Court’s decision and thus remains in effect. See Shadix v.

Carroll County, 274 Ga. 560, 563-564 (1) (554 SE2d 465) (2001). For the reasons that

follow, we reverse.

As set forth in the Supreme Court’s opinion, the record shows that

In the second amended complaint, the State alleged that SmithCo Recycling and SmithCo Transfer were companies conducting business in Georgia, and that Garrett Smith and Stacey Smith were involved in the day-to-day business and operations of both companies as co-owners, registered agents, or managing members. The State further alleged that, on various occasions, SmithCo Recycling, through its owners or agents,

3 purchased catalytic converters or other regulated metals that they “knew or should have known were stolen”; that Garrett Smith enlisted third parties to purchase scrap vehicles or stolen catalytic converters for resale to SmithCo Recycling; that a SmithCo Recyling employee stole roll-off containers and sold them to SmithCo Recycling; that purchase transactions were completed “without the requisite documentation”; and that SmithCo Recycling failed to report certain purchase transactions to the Georgia Bureau of Investigation (“GBI”). Based on different combinations of these allegations, the State alleged violations of numerous statutes, including OCGA § 10-1-351 (regulating the purchase of coils, copper wire, and catalytic converters), OCGA § 10-1- 353 (requiring secondary metals recyclers to maintain records of purchase transactions), OCGA § 10-1-359.1 (requiring registration of secondary metals recyclers), OCGA § 10-1-359.5 (requiring secondary metals recyclers to provide purchase-transaction information to the GBI), OCGA § 40-3-36 (regulating the disposal of vehicles), OCGA § 16-4-8 (conspiracy to commit a crime), OCGA § 16-8-2 (theft by taking), OCGA § 16-8-4 (theft by conversion), OCGA § 16-8-7 (theft by receiving stolen property), OCGA § 16-8-83 (chop shop offenses), and OCGA § 16-14-4 (Racketeer Influenced and Corrupt Organizations Act offenses).

Smith II, 319 Ga. at 354 (1).

In actions in rem, the complaint must “allege the essential elements of the

criminal violation which is claimed to exist[.]” OCGA § 9-16-12 (a). “Because it is a

4 special statutory proceeding, we are required to strictly construe the forfeiture

statute.” State v. Henderson, 263 Ga. 508, 509 (436 SE2d 209) (1993) (construing

former forfeiture statute). Although the State’s second amended complaint alleges

violations of a number of statutes, it does not allege the essential elements of any

criminal violation as required by OCGA § 9-16-12 (a). For example, the second

amended complaint alleges that SmithCo Recycling bought catalytic converters in

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Related

State v. Henderson
436 S.E.2d 209 (Supreme Court of Georgia, 1993)
Shadix v. Carroll County
554 S.E.2d 465 (Supreme Court of Georgia, 2001)
Pender v. State
856 S.E.2d 302 (Supreme Court of Georgia, 2021)

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