Kristine Heath v. State

CourtCourt of Appeals of Georgia
DecidedMarch 21, 2019
DocketA18A2112
StatusPublished

This text of Kristine Heath v. State (Kristine Heath 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
Kristine Heath v. State, (Ga. Ct. App. 2019).

Opinion

FIFTH DIVISION MCFADDEN, P. J., RICKMAN and MARKLE, 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. http://www.gaappeals.us/rules

March 4, 2019

In the Court of Appeals of Georgia A18A2112. HEATH v. THE STATE.

MCFADDEN, Presiding Judge.

After a jury trial, Kristine Heath was convicted of homicide by vehicle in the

first degree, homicide by vehicle in the second degree, five counts of serious injury

by vehicle, and failure to stop for a stop sign.1 The trial court denied Heath’s motion

1 The events leading to Heath’s convictions occurred on June 17, 2011. Judgment of conviction was entered August 14, 2013, and Heath filed a motion for new trial on September 13, 2013. On March 17, 2014, she filed a motion to amend her sentence under OCGA § 17-10-1 (f), which the trial court granted on July 23, 2014, reducing her sentence from its original term of 20 years of imprisonment followed by 10 years of probation to a new term of 15 years of imprisonment followed by 15 years of probation. New counsel amended the motion for new trial on March 13, 2017, and again on February 19, 2018. The trial court denied the motion for new trial on May 1, 2018, Heath filed a notice of appeal on May 11, 2018, and the case was docketed in this court on July 11, 2018. Heath was released on parole after five years of incarceration on August 24, 2018. for new trial and she filed this appeal. She argues that the evidence was insufficient

to support the felony convictions; that she received ineffective assistance of counsel;

that she was deprived of her right to be present at all critical stages of the trial; and

that the court plainly erred by failing to instruct the jury on proximate cause.

We reverse Heath’s convictions for homicide by vehicle in the first degree,

homicide by vehicle in the second degree, and serious injury by vehicle because her

trial counsel provided ineffective assistance by failing to demur to fatally defective

counts in the indictment. We do not reach the other claims of error that affect only the

convictions based on those counts. We affirm Heath’s conviction for failure to stop at

a stop sign.

1. Facts and procedural posture.

Viewed in the light most favorable to the jury’s verdict, Cunningham v. State,

304 Ga. 789, 790 (822 SE2d 281) (2018), the evidence showed that Heath was

The more than 4½-year delay in ruling on Heath’s motion for new trial is not fully explained. It is the duty of the trial court and the parties to ensure that post-conviction motions are decided without unnecessary delay. See Owens v. State, 303 Ga. 254 (4) (811 SE2d 420) (2018). Effective January 1, 2019, amended Uniform Superior Court Rule 41.2 places upon the trial court the “responsibility to monitor the progress of the case.” The amended rule requires the trial court to schedule status conferences regarding the motion for new trial approximately every 180 days until the motion is heard. Uniform Superior Court Rule 41.2.

2 attending a family reunion at Clarks Hill Lake the weekend of June 17, 2011. She

arrived Friday evening.

Heath and her group left to go to a restaurant for dinner. Heath drove the group

in her vehicle, traveling on Ridge Road towards its intersection with Washington

Road three or four miles away. The intersection is governed by a stop sign.

Heath was driving about forty miles per hour, five miles below the posted speed

limit. She rounded the last curve before the intersection, drove a 220-foot

straightaway, and then ran the stop sign without slowing down; she never applied the

brakes.

Heath collided with a Jeep Cherokee traveling on Washington Road in which

a driver and five passengers were riding. In the collision, the driver of the Cherokee

injured her knees, broke her ankle, broke ribs, and suffered lacerations to her liver.

One of the passengers damaged her spleen and liver, bruised her heart, punctured a

lung, and broke ribs. A second passenger in the Cherokee broke pelvic bones and

fractured an eye socket.

In Heath’s vehicle, one passenger was killed. A second passenger suffered a

crushed pelvis and a separation between his sacrum and hip, and lacerated his liver

and a kidney. A third passenger broke his pelvis and suffered a contusion to his head.

3 Heath was charged with one count of homicide by vehicle in the first degree

(OCGA § 40-6-393 (a)) based on reckless driving (OCGA § 40-6-390); one count of

homicide by vehicle in the first degree (OCGA § 40-6-393 (a)) based on driving under

the influence of alcohol (OCGA § 40-6-391); six counts of serious injury by vehicle

(OCGA § 40-6-394) based on reckless driving (OCGA § 40-6-390) and driving under

the influence of alcohol (OCGA § 40-6-391); failure to stop at a stop sign (OCGA §

40-6-72); and violation of the open container law (OCGA § 40-6-253). The trial court

granted the state’s request for entry of nolle prosequi on one of the serious-injury-by-

vehicle counts and the open-container count.

The jury found Heath guilty of homicide by vehicle in the first degree based on

reckless driving; five counts of serious injury by vehicle; and failure to stop at a stop

sign. It found Heath guilty of homicide by vehicle in the second degree as a lesser-

included offense of homicide by vehicle in the first degree based on driving under the

influence of alcohol. The trial court merged the second-degree homicide-by-vehicle

conviction and the failure-to-stop-at-a-stop-sign conviction, and sentenced Heath to

a total of 15 years imprisonment followed by 15 years probation. In a brief order, the

trial court denied Heath’s motion for new trial, and this appeal followed.

2. Ineffective assistance of counsel.

4 Heath argues that trial counsel was ineffective for failing to file a general

demurrer to the felony counts of the indictment. We agree and reverse the convictions

entered on those counts.

To establish an ineffective assistance claim, an appellant must show not only that [her] counsel’s performance was deficient but also that the deficiency so prejudiced [her] as to create a reasonable probability that but for counsel’s errors, the outcome of the trial would have been different. Failure to satisfy both requirements is fatal to an ineffectiveness claim.

Everhart v. State, 337 Ga. App. 348, 353 (3) (786 SE2d 866) (2016) (citation

omitted).

Heath argues that trial counsel was ineffective for failing to file a general

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Polk v. State
620 S.E.2d 857 (Court of Appeals of Georgia, 2005)
Howard v. State
555 S.E.2d 884 (Court of Appeals of Georgia, 2001)
Ross v. State
508 S.E.2d 424 (Court of Appeals of Georgia, 1998)
Smith v. Hardrick
464 S.E.2d 198 (Supreme Court of Georgia, 1995)
Lee v. State
634 S.E.2d 837 (Court of Appeals of Georgia, 2006)
Mikenney v. State
586 S.E.2d 328 (Supreme Court of Georgia, 2003)
Borders v. State
514 S.E.2d 14 (Supreme Court of Georgia, 1999)
State v. Outen
764 S.E.2d 848 (Supreme Court of Georgia, 2014)
Everhart v. the State
786 S.E.2d 866 (Court of Appeals of Georgia, 2016)
Jackson v. State
800 S.E.2d 356 (Supreme Court of Georgia, 2017)
Owens v. State
811 S.E.2d 420 (Supreme Court of Georgia, 2018)
Goodrum v. State
812 S.E.2d 220 (Supreme Court of Georgia, 2018)
Cunningham v. State
822 S.E.2d 281 (Supreme Court of Georgia, 2018)
Brown v. State
745 S.E.2d 699 (Court of Appeals of Georgia, 2013)
Cunningham v. State
304 Ga. 789 (Supreme Court of Georgia, 2018)
Owens v. State
303 Ga. 254 (Supreme Court of Georgia, 2018)
Goodrum v. State
303 Ga. 414 (Supreme Court of Georgia, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Kristine Heath v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kristine-heath-v-state-gactapp-2019.