Gebhardt v. State

307 Ga. 587
CourtSupreme Court of Georgia
DecidedDecember 23, 2019
DocketS19A1582
StatusPublished
Cited by3 cases

This text of 307 Ga. 587 (Gebhardt 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
Gebhardt v. State, 307 Ga. 587 (Ga. 2019).

Opinion

307 Ga. 587 FINAL COPY

S19A1582. GEBHARDT v. THE STATE.

MELTON, Chief Justice.

Following a June 18 to 26, 2018 jury trial, Franklin George

Gebhardt was found guilty of malice murder and various other

offenses in connection with the torture and stabbing death of Tim

Coggins in October 1983.1 On appeal, Gebhardt contends that the

1 On March 19, 2018, Gebhardt was jointly indicted with William Franklin Moore for malice murder, felony murder predicated on aggravated assault, aggravated battery, aggravated assault, and concealing the death of another. Moore’s trial was severed from Gebhardt’s, and Moore entered a negotiated guilty plea. Following the June 18 to 26 jury trial, Gebhardt was found guilty on all counts. Gebhardt was sentenced to life for malice murder, 20 consecutive years for aggravated battery, and ten consecutive years for concealing the death of another. The trial court merged the aggravated assault count into the malice murder count for sentencing purposes and purported to merge the felony murder count into the malice murder count, but that count was actually vacated by operation of law. See Malcolm v. State, 263 Ga. 369, 372 (4) (434 SE2d 479) (1993). Gebhardt timely filed a motion for new trial on July 3, 2018, which he amended on December 21, 2018. Following a hearing, on May 15, 2019, the trial court granted the motion for new trial in part, finding that the aggravated assault, aggravated battery, and concealing the death of another counts had to be vacated on the basis that there was insufficient evidence to show that the statute of limitation was tolled with regard to those crimes after they had been committed in 1983. See OCGA § 17- 3-1 (c) (“Except as otherwise provided in Code Section 17-3-2.1[, which refers to felonies not at issue in this case,] prosecution for felonies other than [murder or other crimes punishable by death or life imprisonment] shall be commenced evidence presented at trial was insufficient to support his murder

conviction; that the trial court erred in denying Gebhardt’s pre-trial

plea in bar with respect to the charges of aggravated assault,

aggravated battery, and concealing the death of another; that the

trial court inappropriately commented on the evidence at trial; and

that the trial court committed several evidentiary errors. For the

reasons that follow, we affirm.

1. Viewed in the light most favorable to the jury’s verdict, the

evidence presented at trial reveals that, on the evening of October 7,

1983, Coggins, an African-American man, visited a club in Spalding

County with predominantly African-American clientele. On the way

to the club, Coggins told a friend who drove him to the club about a

within four years after the commission of the crime, provided that prosecution for felonies committed against victims who are at the time of the commission of the offense under the age of 18 years shall be commenced within seven years after the commission of the crime.”). See also OCGA § 17-3-2 (identifying circumstances for tolling the statute of limitation with respect to the time period within which a crime must be prosecuted). The trial court denied the motion for new trial with respect to the felony murder and malice murder counts, but also vacated the felony murder count. See Malcolm, supra, 263 Ga. at 371 (4). Gebhardt is now serving a life sentence for malice murder. Gebhardt filed a timely notice of appeal on May 24, 2019, and his appeal was docketed to the August 2019 term of this Court and submitted for a decision on the briefs.

2 Caucasian woman, Ruth Guy, whom Coggins was dating at the time.

When Coggins arrived at the club, three white males — Gebhardt,

Moore, and another man — were waiting outside. Guy was

Gebhardt’s ex-girlfriend, and Gebhardt did not approve of Coggins’s

interracial relationship with her. Coggins knew Gebhardt and

Moore, and he approached the men before entering the club, but no

confrontation occurred between Gebhardt and Coggins at that time.

After Coggins danced at the club for a while, Gebhardt came in

looking for Coggins, and, eventually, Coggins left the club with

Gebhardt and the other men with whom Gebhardt had been

standing outside. Coggins called his friend, Samuel Freeman, and

told Freeman that he was with “Frankie,” whom Freeman knew to

be Gebhardt. Coggins, Gebhardt, Moore, and the other man with

whom Gebhardt and Moore had been standing traveled to a nearby

party before heading to a mobile home park in Sunnyside, close to

where Gebhardt lived.

In the early morning hours of October 8, Gebhardt began

arguing with Coggins in the mobile home park, with Moore and Guy

3 present as well. Moore and Guy then got into the front of a car, and

Gebhardt and Coggins got into the back seat, and the group started

driving in the direction of Minter Road. When Gebhardt and Moore

arrived in an area near Minter Road with Coggins, but apparently

no longer with Guy, Gebhardt and Moore stabbed Coggins multiple

times in the back, torso, wrist, and neck; chained Coggins to the back

of their truck and dragged him behind it; and then stabbed Coggins

some more. Coggins died from his stab wounds, and Moore and

Gebhardt left Coggins’s body in a field in a rural area that was

intersected by a power line and that was about a mile away from the

mobile home park.

Coggins’s body was found the next day by Christopher Vaughn,

who was out hunting squirrels with his father at the time. Coggins

was still wearing his underwear and jeans, but he was without his

shirt, socks, and shoes. Police were called to the scene, and they

found Coggins’s blood-stained beige sweater there. Drag marks

around a dirt trail in a pattern that ended at Coggins’s body were

consistent with a person having been dragged behind a truck, and

4 abrasions on Coggins’s body indicated that he had been dragged.

However, police did not find any item that could have been used to

drag Coggins behind a truck at that time.

Despite the preliminary investigation by police into the

murder, the case went cold after about four or five months.2 Over

the subsequent years, Gebhardt bragged about having murdered

Coggins for being involved with Guy, and he provided details about

the murder that had not been made known to the public. Two weeks

after the murder, Gebhardt admitted to a friend named Willard

Sanders that Gebhardt and Moore had killed Coggins and dragged

him along the power line after tying a logging chain around

Coggins’s feet. And, a few months after the murder, Gebhardt

admitted to Vaughn at a party that he and Moore had killed the man

that Vaughn had found “over there on the power line.” Gebhardt also

2 Clint Phillips, the lead investigator with the Spalding County Sheriff’s

Office on Coggins’s murder case in 1983, later testified at Gebhardt’s trial that Coggins’s case was not always a top priority at the Sheriff’s Office, and that Phillips was often pulled off the case to work on less serious crimes in other areas of the county.

5 told Vaughn on at least three or four other occasions that he and

Moore had stabbed “the ni**er,” referring to Coggins, 18 to 30 times,

dragged him down the power lines, and then stabbed him again

because Coggins was romantically involved with Guy. In addition,

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Bluebook (online)
307 Ga. 587, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gebhardt-v-state-ga-2019.