Jasmine Brown v. State

CourtCourt of Appeals of Georgia
DecidedMarch 13, 2020
DocketA19A2359
StatusPublished

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Bluebook
Jasmine Brown v. State, (Ga. Ct. App. 2020).

Opinion

FIFTH DIVISION MCFADDEN, C. J., MCMILLIAN, P. J., and SENIOR APPELLATE JUDGE PHIPPS

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

March 13, 2020

In the Court of Appeals of Georgia A19A2359. BROWN v. THE STATE.

MCFADDEN, Chief Judge.

This appeal challenges the denial of a plea in bar which asserted double

jeopardy grounds after the first trial of the defendant ended with the trial judge’s sua

sponte declaration of a mistrial due to a violation of the rule of sequestration. Because

there was no manifest necessity for a mistrial, the defendant may not be tried again

on the same charges. Accordingly, the trial court erred in denying the plea in bar.

1. Facts and procedural posture.

Jasmine Brown was charged by accusation with two counts of battery and four

counts of reckless conduct arising out of an altercation that allegedly occurred on

November 3, 2016. The case proceeded to a jury trial on March 23, 2018. At the

outset of the trial, Brown’s counsel invoked the rule of sequestration, and the trial court instructed any witnesses in the case to leave the courtroom. The state then

presented its case-in-chief and rested.

As the defense prepared to call its two witnesses, who were located in a

conference room adjacent to the courtroom, the judge indicated that the door to the

conference room had not been closed. The judge sent the jury to the jury room,

brought the two defense witnesses into the courtroom, and asked them how long they

had been in the conference room. Both witnesses indicated that they had been in the

room approximately two hours. The judge asked if they had been able to hear her

voice from the conference room. One of the witnesses said, “A little, but I wasn’t

paying attention.” And the other witness replied, “It goes, but it wasn’t clear.”

The judge then asked the state if it had a motion. The state’s attorney did not

make a motion, but she said that there was a question about whether the rule of

sequestration had been violated and noted that one of the witnesses was also charged

with offenses arising out of the alleged altercation. When the state’s attorney

continued discussing that witness, the trial judge cut her off and sua sponte declared

a mistrial. The judge announced: “This case is mistried. I’m declaring a mistrial at

this moment. The case is mistried and I will consider rescheduling as well as any

other additional matters next week.” The judge then called the jurors back into the

2 courtroom, told them that there was a mistrial because there had been a violation of

the rule of sequestration, and dismissed the jury.

After the jury had left, the court reporter told the judge that she thought the two

witnesses had approached her after lunch and asked “in general how they would go

about getting what was said in the trial.” The judge indicated that she appreciated that

matter being put on the record, but that she wanted to get back to the issue at hand,

which was the rule of sequestration. The judge then announced that there had been

a violation of that rule, that she found the violation to be the responsibility of defense

counsel, and that she was holding both defense attorneys in contempt of court. The

judge refused the attorneys’ request for a hearing at a later date with the assistance

of counsel and asked them if they had anything “to say about the actual contempt at

this time[.]” After both attorneys denied being in contempt, the judge reiterated her

earlier finding of contempt, fined each of them $175, and adjourned the proceedings.1

Brown subsequently filed a plea in bar, claiming that the trial judge had

improperly declared a mistrial and thus any subsequent prosecution of the case

against her is barred by double jeopardy. After a hearing, the trial judge denied the

1 An appeal from the summary criminal contempt finding against the two defense attorneys is pending before this court. See In re Adams, Case No. A19A1723.

3 plea in bar. In her written order, the judge estimated that the door of the conference

room was located approximately twenty-five to thirty feet from the witness stand and

that the door had been open approximately four to six inches during the trial

proceedings. The judge found, based on her brief questioning of the two defense

witnesses at trial, that they had in fact heard the testimony of the state’s witnesses.

The judge concluded that she had the discretion to declare a mistrial based on such

a violation of the rule of sequestration and that subsequent “[p]rosecution of the case

is not barred by double jeopardy.” Brown appeals from that ruling.

2. Double jeopardy.

Brown asserts that the trial judge erred in denying her plea in bar because the

double jeopardy provisions of the federal constitution, the Georgia constitution, and

the Georgia code prohibit another trial on the same charges after the mistrial.

In determining whether a second trial is permitted on the same charges following a mistrial, our case law has treated all forms of double jeopardy claims, whether under the Constitution of the United States, under the Georgia Constitution, or under the Georgia Code, in a manner consistent with case law from the United States Supreme Court regarding the Fifth Amendment, and we do so below regarding [Brown’s] claims.

Carman v. State, 304 Ga. 21, 25 (2) (815 SE2d 860) (2018).

4 “The Double Jeopardy Clause of the Fifth Amendment, which applies to the

states through the Fourteenth Amendment, says ‘[n]o person shall be . . . subject for

the same offence to be twice put in jeopardy of life or limb.’” Meadows v State, 303

Ga. 507, 510 (2) (813 SE2d 350) (2018) (citations and punctuation omitted). See also

Ga. Const. of 1983, Art. I, Sec. I, Par. XVIII (“No person shall be put in jeopardy of

life or liberty more than once for the same offense. . . .”); OCGA § 16-1-8 (a) (2) (“A

prosecution is barred if the accused was formerly prosecuted for the same crime based

upon the same material facts, if such former prosecution . . . [w]as terminated

improperly after the jury was impaneled and sworn[.]).

[P]rotection against double jeopardy recognizes the valued right of a criminally accused, once [her] jury has been sworn and impaneled and thus jeopardy has attached, to have [her] trial proceed to acquittal or conviction before that tribunal. The trial judge, therefore, must always temper the decision whether or not to abort a trial by considering the importance to the defendant of being able, once and for all, to conclude [her] confrontation with society through the verdict of a tribunal [she] might believe to be favorably disposed to [her] fate. For these reasons, to avoid barring a second trial, the court may declare a mistrial without a defendant’s consent or over [her] objection only when taking all the circumstances into consideration, there is a manifest necessity for doing so, which means a high degree of necessity.

Meadows, supra at 511 (2) (citations and punctuation omitted). “Because of the

severe consequences of ordering a mistrial without the accused’s consent, a trial court

5 should give careful, deliberate, and studious consideration to whether the

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Bluebook (online)
Jasmine Brown v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jasmine-brown-v-state-gactapp-2020.