Mark Joseph Tatum v. State

CourtCourt of Appeals of Georgia
DecidedApril 17, 2023
DocketA23A0526
StatusPublished

This text of Mark Joseph Tatum v. State (Mark Joseph Tatum 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
Mark Joseph Tatum v. State, (Ga. Ct. App. 2023).

Opinion

THIRD DIVISION DOYLE, P. J., GOBEIL, 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. https://www.gaappeals.us/rules

April 17, 2023

In the Court of Appeals of Georgia A23A0526. TATUM v. THE STATE.

GOBEIL, Judge.

Following a bench trial, Mark Joseph Tatum was convicted of being a “peeping

Tom” and invasion of privacy. On appeal, Tatum argues that the trial court erred in

denying his motion to suppress/motion in limine regarding the contents of his cell

phone because the arresting deputy illegally accessed a video on his cell phone absent

a search warrant; and the later-obtained warrant was tainted as fruit of the poisonous

tree because it was based on the deputy’s observations during the initial warrantless

search. For the reasons that follow, we affirm.

We apply the following principles upon appellate review of a ruling on a

motion to suppress: First, when a motion to suppress is heard by the trial judge, that judge sits as the trier of facts. The trial judge hears the evidence, and his findings based upon conflicting evidence are analogous to the verdict of a jury and should not be disturbed by a reviewing court if there is any evidence to support them. Second, the trial court’s decision with regard to questions of fact and credibility must be accepted unless clearly erroneous. Third, the reviewing court must construe the evidence most favorably to the upholding of the trial court’s findings and judgment. These principles apply equally whether the trial court ruled in favor of the State or the defendant.

Brown v. State, 293 Ga. 787, 803 (3) (b) (2) (750 SE2d 148) (2013) (citation and

punctuation omitted). When “the evidence at a suppression hearing is uncontroverted

and the credibility of witnesses is not in question, we conduct a de novo review of the

trial court’s application of the law to the undisputed facts.” Jones v. State, 291 Ga. 35,

36-37 (1) (727 SE2d 456) (2012).

The uncontroverted evidence adduced at the motion to suppress hearing and

stipulated to by the parties shows that on July 15, 2018, at 10:34 p.m., the Madison

County 9-1-1 center received a call regarding an unknown individual taking

photographs or recording with a cell phone through the bedroom of an 18-year-old

female resident. Will Townsend, a deputy with the Madison County Sheriff’s Office,

was dispatched to the location. Deputy Townsend encountered an individual, later

2 identified as Tatum, walking in the vicinity of the complainant’s residence. Townsend

stopped his vehicle and asked Tatum what he was doing, and Tatum responded that

he was “out walking around.” Tatum initially denied that he had a cell phone on his

person. Townsend observed the outline of an object that appeared to be a cell phone

in Tatum’s front pants pocket. When asked about the object, Tatum pulled out a cell

phone from his pocket and claimed that he had forgotten that he had his phone on

him. Townsend noticed that Tatum’s cell phone had a camera lens in the center of the

back of the phone similar to the one reported by the 911 caller.

Deputy Townsend asked Tatum if he would be willing to show him the last

picture he had taken on his phone. After some back-and-forth, Tatum agreed to pull

up the photo gallery and show the deputy. As Tatum was on his phone, he tilted the

phone away from the deputy. Townsend noticed that Tatum’s hand was shaking and

he appeared “extremely” nervous. Townsend observed a thumbnail-size photograph

of a girl standing by a window in a room. Based on his belief that Tatum was trying

to delete something, Townsend seized the cell phone from Tatum’s hand “to preserve

the evidence.” The deputy went back to his patrol car and viewed a video on Tatum’s

phone, which depicted a female standing in a bedroom, with her breasts exposed,

folding laundry. Townsend locked the screen and did not further search the phone.

3 Law enforcement later obtained and executed a search warrant to view the contents

of Tatum’s phone, and recovered photographs and a video showing a woman folding

laundry while not wearing a shirt.

Based on the foregoing, a grand jury returned an indictment charging Tatum

with being a peeping Tom, invasion of privacy, and tampering with evidence. Tatum

filed a motion to suppress/motion in limine to suppress any evidence related to the

contents of his cell phone, arguing in relevant part that the initial warrantless seizure

and search of his cell phone was illegal, and the later obtained warrant was tainted by

the previous illegal search. According to Tatum, any evidence obtained from the cell

phone should be suppressed as “fruit of the poisonous tree.” After a hearing, the trial

court summarily denied the motion.

After a bench trial,1 the trial court found Tatum guilty of being a peeping Tom

and invasion of privacy, and not guilty on the charge of tampering with evidence. He

was sentenced to a total term of ten years with the first two years and six months to

serve in confinement and the remainder on probation. The instant appeal followed.

On appeal, Tatum contends that the arresting deputy’s illegal warrantless

viewing of the video on Tatum’s cell phone tainted the validity of the later-obtained

1 Tatum waived his right to a jury trial and requested a bench trial.

4 search warrant, and therefore, any evidence obtained from the phone should have

been excluded as fruit of the poisonous tree. Tatum does not contest the actual seizure

of the cell phone, but maintains that “[w]hile exigent circumstances may authorize the

warrantless physical seizure of a cell phone, a warrant is still required to access its

contents.” According to Tatum, absent the information concerning the contents of the

video recovered from his cell phone (depicting a topless woman taken from outside

her window), the affidavit underpinning the search warrant was devoid of probable

cause.

In Riley v. California, the U. S. Supreme Court held that the police cannot,

without a warrant, search digital information on a cell phone seized incident to arrest.

573 U. S. 373, 401 (IV) (134 SCt 2473, 189 LE2d 430) (2014). The Court reasoned

that the search incident to arrest exception did not apply because neither rationale —

the interest in protecting officer safety or preventing destruction of evidence —

justified the warrantless search of cell phone data. Id. at 388-391 (III) (A) (1), (2). It

further noted that “[c]ell phones differ in both a quantitative and a qualitative sense

from other objects that might be kept on an arrestee’s person. The term ‘cell phone’

is itself misleading shorthand; many of these devices are in fact minicomputers. . . .”

Id. at 393 (III) (B) (1). Thus, according to the Court, searches of cell phones are far

5 more intrusive than searches prior to the “digital age,” which were “limited by

physical realities and tended as a general matter to constitute only a narrow intrusion

on privacy.” Id. “The fact that technology now allows an individual to carry such

information in his hand does not make the information any less worthy of the

protection for which the Founders fought,” the Court noted. Id. at 403 (IV).

However, the U. S. Supreme Court in Riley recognized that an exception to the

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

Related

O'KEEFE v. State
376 S.E.2d 406 (Court of Appeals of Georgia, 1988)
Langley v. Meredith
376 S.E.2d 519 (Supreme Court of Virginia, 1989)
Clare v. State
217 S.E.2d 638 (Court of Appeals of Georgia, 1975)
Love v. State
659 S.E.2d 835 (Court of Appeals of Georgia, 2008)
Brown v. State
504 S.E.2d 443 (Supreme Court of Georgia, 1998)
Teal v. State
647 S.E.2d 15 (Supreme Court of Georgia, 2007)
Wilder v. State
717 S.E.2d 457 (Supreme Court of Georgia, 2011)
Jones v. State
727 S.E.2d 456 (Supreme Court of Georgia, 2012)
Riley v. Cal. United States
134 S. Ct. 2473 (Supreme Court, 2014)
Brown v. the State
767 S.E.2d 299 (Court of Appeals of Georgia, 2014)
United States v. Alejandro Barron-Soto
820 F.3d 409 (Eleventh Circuit, 2016)
United States v. Brian Robert Harling
705 F. App'x 911 (Eleventh Circuit, 2017)
WINGATE v. the STATE.
819 S.E.2d 502 (Court of Appeals of Georgia, 2018)
Brundige v. State
735 S.E.2d 583 (Supreme Court of Georgia, 2012)
Brown v. State
750 S.E.2d 148 (Supreme Court of Georgia, 2013)
Stephens v. State
816 S.E.2d 748 (Court of Appeals of Georgia, 2018)
Arp v. State
759 S.E.2d 57 (Court of Appeals of Georgia, 2014)
Lofton v. State
854 S.E.2d 690 (Supreme Court of Georgia, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Mark Joseph Tatum v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mark-joseph-tatum-v-state-gactapp-2023.