Michael Clay v. State

CourtCourt of Appeals of Georgia
DecidedJune 3, 2013
DocketA13A0173
StatusPublished

This text of Michael Clay v. State (Michael Clay 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 Clay v. State, (Ga. Ct. App. 2013).

Opinion

FIRST DIVISION ELLINGTON, C. J., PHIPPS, P. J., and BRANCH, J.

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/

June 3, 2013

In the Court of Appeals of Georgia A13A0173. CLAY v. THE STATE.

PHIPPS, Presiding Judge.

Michael Clay appeals his convictions for aggravated assault and serious injury

by vehicle. He contends that the trial court erred by denying his motions for a mistrial

– one made prior to the jury being sworn, and another made during the state’s

presentation of the evidence. We affirm.

Clay was charged in a 17-count indictment with crimes, including false

imprisonment, robbery, aggravated sexual battery, murder, kidnapping with bodily

harm, rape, aggravated sodomy, and aggravated assault, allegedly committed from

2000 to 2006. Clay moved to sever the offenses for trial. The trial court issued an

order pertinently stating, “The District Attorney has agreed that severance would be

appropriate. In that the parties are in agreement, the Court will enter a finding that the

offenses alleged are factually distinguishable but cognizable generally when grouped as related incidents.” Accordingly, the trial court granted the motion to sever, while

joining certain specified offenses for trial.

A redacted indictment showed that Counts 16 and 17 from the original

indictment, which alleged offenses of aggravated assault committed against D. B. and

K. W., respectively, were tried together in this case. As to the charge of aggravated

assault involving D. B., the jury found Clay guilty of the lesser included offense of

serious injury by vehicle; as to the aggravated assault involving K. W., the jury found

Clay guilty as charged.

1. Clay complains that the trial court erred by denying his first motion for a

mistrial, made after several impaneled jurors affirmed that they had been exposed to

a newspaper article about the case.

The trial court has a broad discretion in passing on motions for mistrial, and its ruling will not be disturbed by the appellate courts unless it appears that there has been a manifest abuse of discretion and that a mistrial is essential to the preservation of the right to a fair trial. Where a motion for mistrial is made on the ground of inadmissible matters being placed before the jury, the corrective measure to be taken by the trial court also is largely a matter of discretion, and where proper

2 corrective measures are taken and there is no abuse of that discretion, the refusal to grant a mistrial is not error.1

On Monday, May 11, 2009, after a jury had been impaneled, court proceedings

in the case ended for the day and the jury was excused until the following Monday.

On Monday, May 18, 2009, court proceedings in the case resumed, and the following

occurred. Outside the presence of the jury, defense counsel notified the court that the

day after the jury had been impaneled, an article about the case was published in a

local newspaper;2 defense counsel asked the trial court to “give a general voir dire of

the jury and ask them if they have heard or read anything about the defendant since

jury selection. If there is a positive response, I would ask that that juror or jurors be

1 Edwards v. State, 200 Ga. App. 580, 582 (1) (408 SE2d 802) (1991) (citations and punctuation omitted). 2 The headline of the article read: “Trials begin with assault.” The article stated that there were 17 criminal counts against Clay which were “broken up” because not all were related, that Clay was suspected of being a serial rapist, and that Clay was facing charges that included murder. The article stated that Clay was suspected of a 2006 murder in which a woman was brutally attacked, lapsed into a coma, never regained consciousness, and died; and that according to reports in an earlier edition of the newspaper, DNA evidence allegedly connected Clay to attacks on three other women who had reported being beaten, kicked, and sexually assaulted in 2000 and 2003.

3 individually voir dired.” The prosecution had no objection to defense counsel’s

request.

The jury was brought into the courtroom, and the trial court inquired as

follows:

I welcome you back to this term of court, this week of court, the second week of a two-week session. And I have several questions to ask you and I’ll ask you to please respond by raising your hand. It may have been an article in the newspaper or on the television during that last week concerning this case. Did anyone happen to see that?

Five jurors raised their hands. The trial court excused all the jurors from the

courtroom and individually called into the courtroom each of the five jurors who had

raised his or her hand. Two of the jurors said they had noticed the article but had not

read it; one juror said he had not read the article but had read the headline and had

seen that there were more charges than the two that were mentioned during jury

selection; another juror said that her mother had read the article and told her that the

defendant had been charged with “something like” 19 counts; and another juror said

that she had read the article. Defense counsel moved for a mistrial, asserting that the

article had “undone the severance.” The trial court denied the motion. Thereafter, the

jury entered the courtroom and was sworn.

4 “The time for making a motion for mistrial is not ripe until the case has begun,

and the trial does not begin until the jury has been impaneled and sworn. Therefore,

the trial court correctly refused to declare a mistrial.”3 “However, this court has held

that even though the counsel failed to follow the correct procedure or to use the

proper procedural tool, we will not rely upon his inaccurate nomenclature, where the

relief sought in a motion is clear.”4 Because Clay’s motion for mistrial came after

each exposed juror had been individually examined, we view the motion as a

challenge to the poll, which is “directed solely to an objection . . . in [an] individual

juror.”5

Challenges to the poll, the individual juror, are either peremptory or for cause. Challenges for cause are made in one of two forms -- for principal cause or for favor. Principal cause is disqualification based on the

3 Sharpe v. State, 272 Ga. 684, 687 (5) (531 SE2d 84) (2000) (citations and punctuation omitted). 4 Swint v. State, 199 Ga. App. 515, 516 (405 SE2d 333) (1991) (citations and punctuation omitted); Sharpe, supra at 687 (5) (recognizing existence of authority for disregarding the nomenclature of a defendant’s premature motion for mistrial when the import of the motion is clear); Hughey v. State, 180 Ga. App. 375, 377-378 (2) (348 SE2d 901) (1986). 5 Thompson, 109 Ga. 272, 279 (34 SE 579) (1899) (citation omitted); Cauley v. State, 130 Ga. App. 278, 281 (1) (a) (203 SE2d 239) (1973) (“A challenge to the poll is one peremptory or for cause, addressed to an individual juror.”) (citation omitted).

5 grounds enumerated in OCGA § 15-12-163, i.e., the juror is not a citizen, is under 18 years of age, is incompetent because of mental illness, retardation or intoxication, or is so near in kinship to the prosecutor or accused as to disqualify him.

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Related

Lawler v. State
576 S.E.2d 841 (Supreme Court of Georgia, 2003)
Roach v. State
147 S.E.2d 299 (Supreme Court of Georgia, 1966)
Swint v. State
405 S.E.2d 333 (Court of Appeals of Georgia, 1991)
DeYoung v. State
493 S.E.2d 157 (Supreme Court of Georgia, 1997)
Edwards v. State
408 S.E.2d 802 (Court of Appeals of Georgia, 1991)
Cauley v. State
203 S.E.2d 239 (Court of Appeals of Georgia, 1973)
Williams v. State
149 S.E.2d 449 (Supreme Court of Georgia, 1966)
Cromartie v. State
514 S.E.2d 205 (Supreme Court of Georgia, 1999)
Hughey v. State
348 S.E.2d 901 (Court of Appeals of Georgia, 1986)
Harris v. State
344 S.E.2d 528 (Court of Appeals of Georgia, 1986)
Barnes v. State
496 S.E.2d 674 (Supreme Court of Georgia, 1998)
Sharpe v. State
531 S.E.2d 84 (Supreme Court of Georgia, 2000)
Huckabee v. State
699 S.E.2d 531 (Supreme Court of Georgia, 2010)
Thompson v. State
34 S.E. 579 (Supreme Court of Georgia, 1899)
Foster v. State
379 S.E.2d 634 (Court of Appeals of Georgia, 1989)
Tate v. State
564 S.E.2d 495 (Court of Appeals of Georgia, 2002)

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Bluebook (online)
Michael Clay v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-clay-v-state-gactapp-2013.