Michael Brahnan Lovell v. State

CourtCourt of Appeals of Georgia
DecidedMarch 8, 2024
DocketA23A1484
StatusPublished

This text of Michael Brahnan Lovell v. State (Michael Brahnan Lovell 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
Michael Brahnan Lovell v. State, (Ga. Ct. App. 2024).

Opinion

FIRST DIVISION BARNES, P. J., LAND and WATKINS, 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

March 8, 2024

In the Court of Appeals of Georgia A23A1484. LOVELL v. THE STATE.

WATKINS, Judge.

Michael Lovell pled guilty to three counts of obscene Internet contact with a

child, seven counts of sexual exploitation of children, and two counts of electronically

furnishing obscene material to minors.1 On appeal, Lovell argues that the trial court

erred in denying him the opportunity to present additional mitigating evidence after

we remanded for resentencing on his first direct appeal.2 Because Lovell had the

opportunity to and did present mitigating evidence at a previous sentencing hearing,

we affirm.

1 See OCGA §§ 16-12-100.2 (e); 16-12-100 (b); 16-12-100.1 (b). 2 See Lovell v. State, Case No. A22A0932 (August 26, 2022) (unpublished). According to the factual basis for the plea, Lovell created a fake social media

profile and pretended to be a 15-year-old boy in order to contact other minors over the

Internet, which he used to trade and distribute photographs with five underage girls.

He also used the fake account to engage in explicit descriptions of sexual conduct with

the victims. Lovell pled guilty, and the court decided to hold a separate sentencing

hearing.

At the subsequent hearing, Lovell’s plea counsel was not present and sought a

continuance, but agreed to waive her presence to allow the trial court to hear and

consider victim impact statements. Lovell, who was present via Skype due to the

COVID-19 pandemic, agreed to proceed in this manner. The trial court heard the

victim impact statements and rescheduled the sentencing for a later date.

Before the rescheduled hearing took place, additional counsel entered the case

on Lovell’s behalf, and Lovell filed a motion to withdraw his guilty plea. At the

sentencing hearing, the court considered arguments on withdrawing his guilty plea,

and later denied the motion. Lovell also objected that he was not represented at the

first sentencing hearing, so the court struck the prior victim impact statements and

heard them a second time. Lovell then presented evidence in mitigation, which

2 consisted of testimony from Lovell’s father, ten letters from members of the

community, and four letters from three of Lovell’s therapists.3 At a later hearing, the

court imposed a total sentence of 50 years, with the first 49 years to be served in

confinement.

In his first direct appeal, we affirmed the trial court’s denial of Lovell’s motion

to withdraw his guilty plea and rejected his claims for ineffective assistance of counsel.

However, we vacated the portions of his sentence that did not contain split sentences

— sentences consisting of a term of imprisonment followed by at least one year of

probation — because the statute at the time of the offenses required a split sentence

for each conviction. We thus remanded for resentencing to comply with this split-

sentence requirement.4

At the sentencing hearing on remand, the court indicated that it had prepared

an amended sentence and was ready to announce it to the parties. Defense counsel

requested the opportunity to present additional mitigation evidence, which included

testimony from eight witnesses. Counsel argued that Lovell was entitled to a factual

3 The letters are not part of the appellate record. 4 See Lovell, Case No. A22A0932. 3 sentencing hearing because this Court had vacated his sentences on appeal. The trial

court denied his motion to have a “full-blown” hearing, finding that Lovell already

had a sentencing hearing where he presented mitigation evidence. The court also

noted that “the new sentence . . . just corrects the errors in the old sentence.” The

court imposed a total sentence of 42 years’ imprisonment. This appeal followed.

In his sole claim of error on appeal, Lovell argues that the trial court erred in

denying him the opportunity to present additional mitigating evidence, including new

evidence developed since the previous sentencing hearing, after we remanded for

resentencing on his first direct appeal. He contends that this denial violated his due

process rights and OCGA § 17-10-2 (a) (1). We disagree.

We review questions of law de novo.5 OCGA § 17-10-2 (a) (1) provides that:

Except in cases in which the death penalty may be imposed, upon the return of a verdict of “guilty” by the jury in any felony case, the judge shall dismiss the jury and shall conduct a presentence hearing at which the only issue shall be the determination of punishment to be imposed. In the hearing the judge shall hear additional evidence in extenuation, mitigation, and aggravation of punishment, including the record of any prior criminal convictions and pleas of guilty or nolo contendere of the accused, or the absence of any prior conviction and pleas.

5 Tanksley v. State, 362 Ga. App. 767, 768 (870 SE2d 92) (2022). 4 Lovell has cited to no Georgia case — and we have found none — that requires

a trial court to hear additional mitigation evidence following remand for resentencing.

First, by its terms, OCGA § 17-10-2 (a) (1) does not even apply to Lovell, because the

statute requires a presentence hearing only after a verdict “by the jury in any felony

case.”6 Thus, OCGA § 17-10-2 (a) (1) “does not reach sentencing following guilty

pleas.”7 Even if the statute did apply, it only requires “a presentence hearing.”8

“OCGA § 17-10-2 provides that a trial judge must conduct a pre-sentence hearing to

determine punishment, and the record shows that such a hearing was held.”9

Nor has Lovell identified a due process right requiring the trial court to consider

additional mitigation evidence.10 “Due process guarantees that a defendant will be

6 OCGA § 17-10-2 (a) (1). 7 (Citation and punctuation omitted.) McIntosh v. State, 287 Ga. App. 293, 296 (651 SE2d 207) (2007); accord Gilbert v. State, 245 Ga. App. 544, 546 (2) (538 SE2d 104) (2000) (“OCGA § 17-10-2 (a) does not reach sentencing following guilty pleas, its terms applying only in those cases in which sentence is imposed after a jury trial, a bench trial or probation revocation proceedings for a first offender.”). 8 (Emphasis supplied.) OCGA § 17-10-2 (a) (1). 9 Scott v. State, 213 Ga. App. 84, 88 (5) (444 SE2d 96) (1994).

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

Related

Scott v. State
444 S.E.2d 96 (Court of Appeals of Georgia, 1994)
Gilbert v. State
538 S.E.2d 104 (Court of Appeals of Georgia, 2000)
McINTOSH v. State
651 S.E.2d 207 (Court of Appeals of Georgia, 2007)
Castillo-Solis v. State
740 S.E.2d 583 (Supreme Court of Georgia, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Michael Brahnan Lovell v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-brahnan-lovell-v-state-gactapp-2024.