Metz v. State

915 S.E.2d 613, 321 Ga. 402
CourtSupreme Court of Georgia
DecidedMay 6, 2025
DocketS25A0055
StatusPublished

This text of 915 S.E.2d 613 (Metz 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
Metz v. State, 915 S.E.2d 613, 321 Ga. 402 (Ga. 2025).

Opinion

321 Ga. 402 FINAL COPY

S25A0055. METZ v. THE STATE.

BETHEL, Justice.

George Metz traveled to the Paulding County Residential

Substance Abuse Treatment Facility (the “Facility”) to film its

operation for publication on his YouTube channel. After

approaching and then crossing the Facility’s demarcated guard line,

Metz refused orders from both Facility guards and, subsequently,

Paulding County Sheriff’s deputies to exit the property. As a result,

Metz was arrested and charged with loitering near inmates in

violation of OCGA § 42-5-17, as well as obstructing an officer.1 Prior

to trial, Metz filed a general demurrer seeking to bar his prosecution

on the basis that, as applied to him, OCGA § 42-5-17 is

unconstitutionally void for vagueness in violation of the right to due

1 The entirety of the exchange between Metz and the law enforcement

officers was captured on Metz’s audio-video recording, which was admitted into evidence and published to the jury. process guaranteed by the Fifth and Fourteenth Amendments to the

United States Constitution. The trial court rejected Metz’s challenge

to the statute’s constitutionality and, as such, denied Metz’s

demurrer. A jury found Metz guilty on both counts, and the trial

court denied Metz’s timely motion for new trial. Metz now appeals,

contending that the trial court erred by rejecting his as-applied

challenge to OCGA § 42-5-17 and his request to instruct the jury on

the exercise of First Amendment rights as a defense to the charges.2

For the reasons that follow, we affirm.

1. We turn first to Metz’s as-applied challenge to the

constitutionality of OCGA § 42-5-17.3 The constitutionality of a

statute presents a question of law that we review de novo. See State

v. Holland, 308 Ga. 412, 414 (1) (841 SE2d 723) (2020). It is

2 This case was docketed to the term of this Court beginning in December

2024 and submitted for a decision on the briefs. 3 Metz raised only an as-applied challenge to OCGA § 42-5-17 and did

not challenge its facial constitutionality. See Bello v. State, 300 Ga. 682, 686 (1) (797 SE2d 882) (2017) (“An as-applied challenge addresses whether a statute is unconstitutional on the facts of a particular case or to a particular party,” whereas a facial challenge requires showing “that no set of circumstances exists under which the statute would be valid, i.e., that the law is unconstitutional in all of its applications, or at least that the statute lacks a plainly legitimate sweep.” (citations and punctuation omitted)). 2 axiomatic that “all presumptions are in favor of the constitutionality

of a statute[.]” Ga. Dept. of Human Svcs. v. Steiner, 303 Ga. 890, 894-

895 (II) (815 SE2d 883) (2018). “[B]efore an Act of the legislature can

be declared unconstitutional, the conflict between it and the

fundamental law must be clear and palpable and this Court must be

clearly satisfied of its unconstitutionality.” Id. at 894 (II) (citation

and punctuation omitted). And because a statute is presumed valid,

“the burden is on the party claiming that the law is unconstitutional

to prove it.” Id. at 895 (II).

The Fourteenth Amendment to the United States Constitution

provides that no State shall “deprive any person of life, liberty, or

property, without due process of law[.]” To satisfy due process, the

challenged statute must both “give a person of ordinary intelligence

fair warning that specific conduct is forbidden or mandated” and

“provide sufficient specificity so as not to encourage arbitrary and

discriminatory enforcement.” Smallwood v. State, 310 Ga. 445, 447

(2) (851 SE2d 595) (2020) (citation and punctuation omitted).

Because “[v]ague laws without clear enforcement criteria can result

3 in unfair, discriminatory enforcement,” a statute “that fail[s] to

provide clear warning to the average citizen of what conduct is

criminally forbidden or fail[s] to provide explicit standards for its

enforcement to law enforcement officers” will be invalidated as

unconstitutionally vague. Id. (citation and punctuation omitted).

At issue in this case is OCGA § 42-5-17, which provides that

“[i]t shall be unlawful for any person to loaf, linger, or stand around

where inmates are employed or kept after having been ordered by

the warden, superintendent, or designated representative in charge

of the inmates to desist therefrom.” Pointing to defects he perceives

in the statutory text, Metz argues that the statute fails to articulate

either the fair warning or standards for enforcement necessary to

pass constitutional muster as applied to him. We address — and

reject — each of these arguments in turn.

(a) Metz first argues that OCGA § 42-5-17 is insufficiently

definite in its terms and that it deprived him of the requisite fair

warning that his conduct was prohibited. To that end, Metz argues

that the statutory language did not provide him notice by which to

4 determine what behavior constituted a failure to “desist” from

“loaf[ing], linger[ing], or stand[ing] around” or to ascertain the

precise boundaries of a location “where inmates are . . . kept.” We

are not persuaded.

“It is settled that the fair-warning requirement embodied in

the Due Process Clause prohibits the States from holding an

individual criminally responsible for conduct which he could not

reasonably understand to be proscribed.” Rose v. Locke, 423 U. S. 48,

49 (96 SCt 243, 46 LE2d 185) (1975) (citation and punctuation

omitted; emphasis supplied). We assess “the purported vagueness of

a statute in light of the facts of the particular case—i.e., as applied—

rather than in the abstract.” United States v. Cook, 970 F3d 866, 873

(II) (A) (7th Cir. 2020). So, to succeed on his as-applied challenge in

this context, Metz must demonstrate “that the statute is vague as

applied to his particular conduct.” Smallwood, 310 Ga. at 449 (2)

(citation and punctuation omitted).

First, we look to Metz’s argument that the statutory phrase

“where inmates are . . . kept” did not provide him notice by which to

5 ascertain the precise boundaries of a location “where inmates are . .

. kept.” Of course, the relevant inquiry is not whether Metz had

actual notice, but whether a person in Metz’s place would

“reasonably understand” that inmates are kept within the guard

line of correctional institutions. See Rose, 423 U. S. at 49 (citation

and punctuation omitted). As individuals enter the parking lot at

the Facility, there is a warning sign notifying them that they are

“entering the guard line[.]” This sign specifically references inmates,

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915 S.E.2d 613, 321 Ga. 402, Counsel Stack Legal Research, https://law.counselstack.com/opinion/metz-v-state-ga-2025.