Hightower v. State

883 S.E.2d 335, 315 Ga. 399
CourtSupreme Court of Georgia
DecidedJanuary 18, 2023
DocketS22A0870
StatusPublished
Cited by3 cases

This text of 883 S.E.2d 335 (Hightower 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
Hightower v. State, 883 S.E.2d 335, 315 Ga. 399 (Ga. 2023).

Opinion

315 Ga. 399 FINAL COPY

S22A0870. HIGHTOWER v. THE STATE.

MCMILLIAN, Justice.

Michelle Antoinette Hightower was charged with malice

murder and other crimes in connection with the shooting death of

Michael McGee on September 5, 2017. Hightower’s trial on these

charges began in the Superior Court of Fulton County on March 9,

2020, and four days later, on March 13, after the Chief Judge of the

Atlanta Judicial Circuit issued an order declaring a judicial

emergency due to the continued transmission of the COVID-19

virus, the trial court declared a mistrial in Hightower’s case, over

defense counsel’s objections. Hightower subsequently filed a plea in

bar and motion to dismiss the indictment (collectively, the “Plea in

Bar”), asserting that further prosecution of her case was barred by

the double jeopardy clauses of the state and federal constitutions

because there was no manifest necessity to declare a mistrial and because the trial court did not exercise its discretion or consider

reasonable alternatives prior to declaring the mistrial. Following a

hearing, the trial court denied the Plea in Bar on May 21, 2021, and

Hightower appeals.1 Because we conclude that the trial court acted

within its discretion in determining that there was a manifest

necessity for a mistrial, we affirm.

1. Voir dire in Hightower’s trial began on the morning of

Monday, March 9, 2020, and was completed the next day, on March

10. The jury was then selected and sworn. The same day, counsel

gave their opening statements, and the State presented the

testimony of three witnesses. On Wednesday, March 11, the trial

court heard argument on several motions, and the State presented

two additional witnesses. The parties also conducted voir dire of a

proposed expert witness whom the State wished to call to rebut

Hightower’s defense of battered-person syndrome, and the witness

1 Although Hightower originally filed her appeal in 2021, at Hightower’s

request, the case was remanded to allow for completion of the record, and it was re-docketed under the current case number when it returned to this Court. The case was orally argued on August 23, 2022. 2 was qualified as an expert. The trial court recessed the trial

proceedings for the next day, Thursday, March 12, to allow the

State’s expert to interview Hightower and to allow the parties to

prepare and exchange expert reports on the battered-person

defense.

That evening, Christopher S. Brasher, chief judge of both the

Atlanta Judicial Circuit and the Superior Court of Fulton County,

sent an e-mail notifying all Fulton County superior and state court

judges, the Fulton County District Attorney’s office, and the county’s

Public Defender’s office,2 among others, of his intention to issue an

order declaring a judicial emergency effective Monday, March 16,

which would “suspend the calling and empaneling of all jurors and

the conduct of all jury trials” in Fulton County.

Chief Judge Brasher sent another e-mail at 8:20 a.m. on

Friday, March 13, attaching a copy of his order, which was entered

about an hour later, at 9:23 a.m. The order, citing OCGA § 38-3-61,3

2 Hightower was represented by the Public Defender’s office at trial. 3 OCGA § 38-3-61 (a) empowers an “authorized judicial official” to declare

3 declared a judicial emergency in the Atlanta Judicial Circuit, which

is “composed of the County of Fulton.” OCGA § 15-6-1 (3). This

declaration was based on a “serious health emergency” and a

determination that the emergency “substantially endangers or

infringes upon the normal functioning of the judicial system as it

relates to jury service, . . . and any non-essential matters, unless

they can be conducted via video or teleconferencing.” The order

defined the nature of the emergency as “the continued transmission

of Coronavirus/COVID-19 throughout Fulton County and the

potential infection of those who are required to appear in our courts

and interact with large groups due to jury service.” The order further

provided:

[T]he undersigned hereby makes this declaration of a judicial emergency affecting all courts and clerk’s offices in Fulton County as it relates to jury service, including grand jury service and any non-essential matters, unless they can be conducted via video or teleconferencing. Accordingly, IT IS THE ORDER of the Court that no

judicial emergencies, and OCGA § 38-3-60 (1) (B) defines “[a]uthorized judicial official” to include “[a] chief judge of a Georgia superior court judicial circuit[.]” Chief Judge Brasher signed the Fulton County Order in both his capacities as chief judge of the Superior Court of Fulton County and chief judge of the Atlanta Judicial Circuit. 4 jurors or grand jurors shall report and no jury trials shall be held for a period of thirty (30) days from the date of the entry of this Order [(the “Fulton County Order”)].

(Emphasis in original.)

The proceedings in Hightower’s case later recommenced at 9:51

a.m., outside the presence of the jury, and after addressing

preliminary evidentiary matters, the trial court announced that it

would be taking judicial notice of the Fulton County Order and that

it was also anticipating a similar statewide order from then-Chief

Justice Harold D. Melton of this Court. As a result, the trial court

said it anticipated that it would be declaring a mistrial in

Hightower’s case and asked counsel if they wanted to “place

something on the record.”

The State had no objections, but Hightower’s counsel objected

to the mistrial and asked the court to consider less drastic

alternatives. Defense counsel proposed that the trial continue

through the weekend with the belief that it could be concluded by

Sunday “before the judicial emergency has been declared.” In the

alternative, defense counsel suggested that the trial simply be

5 continued until it could be reconvened with the same jury and a new

trial date set “once the judicial emergency is over.” After the jurors

returned to the courtroom, the trial court informed them of the

Fulton County Order declaring a judicial emergency,4 and

announced that it was declaring a mistrial based on the judicial

emergency. The trial court then released the jury from further

service.5

The following week, on March 19, 2020, the trial court entered

4 The Court explained to the jury that

[t]he existence of the judicial emergency in Fulton County is related to the continued transmission of the coronavirus, COVID- 19 virus, throughout Fulton County and the potential infection of those who are required to appear in our courts and interact with large groups due to jury service including grand jury service or other large nonessential calendars. 5 The then-Chief Justice of this Court issued the first in a series of orders

declaring a statewide judicial emergency the next day, on Saturday, March 14, 2020.

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883 S.E.2d 335, 315 Ga. 399, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hightower-v-state-ga-2023.