Kathryn Schrader v. State

CourtCourt of Appeals of Georgia
DecidedJune 30, 2022
DocketA22A0067
StatusPublished

This text of Kathryn Schrader v. State (Kathryn Schrader v. State) 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
Kathryn Schrader v. State, (Ga. Ct. App. 2022).

Opinion

FIRST DIVISION BARNES, P. J., BROWN and HODGES, 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

June 30, 2022

In the Court of Appeals of Georgia A22A0067. SCHRADER v. THE STATE.

BARNES, Presiding Judge.

This appeal contests the denial of a plea in bar. The trial court found, among

other things, that the plea in bar was not timely filed. Because no reversible error has

been shown in that finding, we affirm.

The background facts are as follows. In 2019, Kathryn Schrader was indicted

on three counts of Computer Trespass. At a trial held in February 2020, the jury was

unable to reach a unanimous verdict, so the judge presiding over the trial declared a

mistrial.

Later that year, on November 6, 2020, the grand jury returned an indictment

charging Schrader with six offenses: (Count 1) Computer Trespass; (Count 2)

Computer Password Disclosure; (Count 3) Computer Theft; (Counts 4 and 5) two counts of Tampering with Evidence; and (Count 6) Violation of Oath of Office by a

Public Officer.1 On December 4, 2020, Schrader was arraigned on that indictment and

entered a plea of not guilty. The following month, the State moved to nolle prosse the

2019 indictment; the trial court granted that motion, entering an order on January 29,

2021.

About a week later, on February 5, 2021, Schrader filed the plea in bar

contending that Counts 2 through 6 (that is, all but the “Computer Trespass” count)

were barred under double jeopardy principles pursuant to OCGA §§ 16-1-7 (b)2 and

16-1-8.

Under OCGA § 16-1-7 (b), if several crimes (1) arising from the same conduct are (2) known to the proper prosecuting officer at the time of commencing the prosecution and are (3) within the jurisdiction of a single court, they must be prosecuted in a single prosecution. A second prosecution is barred under OCGA § 16-1-8 (b) (1) if it is for crimes

1 See generally State v. Outen, 324 Ga. App. 457, 459 (1), n. 1 (751 SE2d 109) (2013) (“A superseding indictment usually refers to an indictment that is returned while a valid indictment is still pending. A new indictment usually refers to an indictment returned after the pending indictment has been dismissed.”). 2 OCGA § 16-1-7 (b) (“If the several crimes arising from the same conduct are known to the proper prosecuting officer at the time of commencing the prosecution and are within the jurisdiction of a single court, they must be prosecuted in a single prosecution. . . .”).

2 which should have been brought in the first prosecution under OCGA § 16-1-7 (b). In order for this procedural aspect of double jeopardy to prohibit a prosecution, all three prongs must be satisfied.

(Citation and punctuation omitted; emphasis supplied.) Daniels v. State, 355 Ga. App.

134, 135-136 (843 SE2d 18) (2020); see Maxwell v. State, 311 Ga. 673, 676-677 (2)

(859 SE2d 58) (2021) (expounding upon procedural double jeopardy). “The

defendant bears the burden of proving procedural double jeopardy, and a court must

make decisions based on the limited facts or representations that are currently

available from the parties.” Maxwell, 311 Ga. at 678 (2).

At a hearing held in this case, Schrader contended that the plea in bar was

timely filed, and that Counts 2 through 6 were prohibited as falling within OCGA §

16-1-7 (b). The trial court rejected Schrader’s positions, and denied the plea in bar.

1. As an initial matter, we note that the prohibition against double jeopardy has

two aspects. See Howard v. State, 301 Ga. App. 230, 231 (687 SE2d 257) (2009).

One aspect prohibits certain successive prosecutions; it is referred to as the

procedural bar against double jeopardy. Id.; see Maxwell, 311 Ga. at 677 (2). The

other aspect prohibits successive punishments for the same offense; it is referred to

3 as the substantive bar against double jeopardy. Howard, 301 Ga. App. at 231; see

Johnson v. State, 313 Ga. 155, 157-158 (3) (868 SE2d 226) (2022).

As indicated above, Schrader’s plea in bar was based on the procedural aspect

of double jeopardy.

2. Schrader contends that the trial court erred by finding that her plea was not

timely raised.

The State counters that Schrader failed to comply with the deadline contained

in OCGA § 17-7-110, which states in full: “All pretrial motions, including demurrers

and special pleas, shall be filed within ten days after the date of arraignment, unless

the time for filing is extended by the court.” As the record shows, Schrader did not

file her plea in bar until two months after her arraignment on the indictment charging

the contested Counts 2 through 6.

(a) Schrader argued at the hearing below that OCGA § 17-7-110 did not render

her plea in bar untimely. As she maintains on appeal, the double jeopardy issue did

not become ripe until January 29, 2021 (when the nolle prosse order was entered,

thereby ending the first prosecution). Given that premise, Schrader claims that her

plea in bar – filed within ten days of when the nolle prosse order was entered – was

timely, asserting further that “a Plea in Bar must be filed before trial.”

4 Schrader’s position lacks merit, however, in light of Davis v. State, 307 Ga.

784 (838 SE2d 233) (2020). In that case, the Supreme Court recited that “[u]nder

Georgia law, a prosecution commences with the return of an indictment or the filing

of an accusation”;3 the Court also defined that a “plea in bar is a challenge to the

validity of an indictment”; and the Court described that the “special” plea in bar in

that case – resting on its premise that, even if all the facts as alleged in the indictment

are true, the defendant could not be held liable due to the applicable statute of

limitation4 – sought to “defeat the prosecutor’s action completely and permanently.”

Id. at 786-787 (2). Further, the Court reasoned, there was nothing for a plea in bar to

defeat “until either an indictment or an accusation [was] filed.” (Emphasis supplied.)

Id. at 786 (2).

3 See generally Coalson v. State, 251 Ga. App. 761, 764 (2) (555 SE2d 128) (2001) (“[T]he purpose of the indictment is to allow defendant to prepare his defense intelligently and to protect him from double jeopardy.”) (punctuation and footnote omitted). 4 See generally Davis v. State, 347 Ga. App. 757, 757 (820 SE2d 791) (2018) (“A special plea in bar is ‘[a] plea that, rather than addressing the merits and denying the facts alleged, sets up some extrinsic fact showing why a criminal defendant cannot be tried for the offense charged.’” (Emphasis added by Davis, supra, quoting Black’s Law Dictionary (10th ed. 2014)) (physical precedent only).

5 Here, Schrader sought to defeat the prosecutor’s actions completely and

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Related

State v. Evans
384 S.E.2d 404 (Court of Appeals of Georgia, 1989)
McCutchen v. State
341 S.E.2d 260 (Court of Appeals of Georgia, 1986)
Coalson v. State
555 S.E.2d 128 (Court of Appeals of Georgia, 2001)
Howard v. State
687 S.E.2d 257 (Court of Appeals of Georgia, 2009)
McClure v. State
345 S.E.2d 922 (Court of Appeals of Georgia, 1986)
Gary v. State
422 S.E.2d 426 (Supreme Court of Georgia, 1992)
Winn v. State
660 S.E.2d 883 (Court of Appeals of Georgia, 2008)
Palmer v. State
651 S.E.2d 86 (Supreme Court of Georgia, 2007)
Nicely v. State
699 S.E.2d 774 (Court of Appeals of Georgia, 2010)
DAVIS v. the STATE.
820 S.E.2d 791 (Court of Appeals of Georgia, 2018)
State v. Dempsey
727 S.E.2d 670 (Supreme Court of Georgia, 2012)
State v. Outen
751 S.E.2d 109 (Court of Appeals of Georgia, 2013)
Davis v. State
838 S.E.2d 233 (Supreme Court of Georgia, 2020)
MAXWELL v. THE STATE (Two Cases)
859 S.E.2d 58 (Supreme Court of Georgia, 2021)
Johnson v. State
868 S.E.2d 226 (Supreme Court of Georgia, 2022)

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Kathryn Schrader v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kathryn-schrader-v-state-gactapp-2022.