Porter v. State

432 S.E.2d 629, 209 Ga. App. 27, 93 Fulton County D. Rep. 2485, 1993 Ga. App. LEXIS 745
CourtCourt of Appeals of Georgia
DecidedJune 11, 1993
DocketA93A0151, A93A0152
StatusPublished
Cited by6 cases

This text of 432 S.E.2d 629 (Porter 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
Porter v. State, 432 S.E.2d 629, 209 Ga. App. 27, 93 Fulton County D. Rep. 2485, 1993 Ga. App. LEXIS 745 (Ga. Ct. App. 1993).

Opinions

Blackburn, Judge.

These are two appeals from the convictions of four co-defendants for trafficking in cocaine. In the case of Porter v. State, Case No. A93A0151, three co-defendants, Porter, Lott, and Hutcheson, appeal their convictions. In Strickland v. State, Case No. A93A0152, Strickland appeals his conviction. We combined the cases because all four co-defendants were tried together and raise substantially the same issues on appeal.1

The evidence used against the defendants was obtained as a result of two investigative warrants, issued by the Gwinnett Superior Court, which authorized a wire interception of three telephone lines. The defendants moved to suppress the tape recordings and the evidence resulting therefrom on the grounds that the warrants allowing the interception and the procedures used for the interception, recording, and storing violated state and federal law.2 The trial court denied defendants’ motion to suppress and defendants were convicted of trafficking in cocaine at the subsequent trial.

1. In their first enumeration of error, all defendants argue that the trial court erred in denying their motion to suppress due to the violations of federal and state law requirements for interception of wire transmissions. Defendants argue initially that the recordings obtained pursuant to the interception warrants were not submitted immediately upon completion to the superior court for judicial sealing as required by 18 USC § 2518 (8) (a).3

Pursuant to the warrants, interceptions were conducted from February 20, 1991 until March 7, 1991. The tapes were not delivered to the superior court judge for sealing until March 28, 1991. On March 28, 1991, the superior court judge inspected the 81 tapes, containing communications intercepted pursuant to the interception warrants, which were brought to him in a sealed condition, having been sealed at some point by the police. The tapes were then sealed in [28]*28boxes in the trial judge’s presence and under his directions. The state offered no explanation for the delay in taking the tapes to the court, other than the testimony of Officer Zimmerman, the lead investigator, who testified that he was unaware that federal law required that the tapes be submitted immediately to the court for sealing.

Federal law requires that “[t]he recording of the contents of any wire, oral, or electronic communication under this subsection shall be done in such way as will protect the recording from editing or other alterations. Immediately upon the expiration of the period of the order, or extensions thereof, such recordings shall be made available to the judge issuing such order and sealed under his directions. Custody of the recordings shall be wherever the judge orders.” (Emphasis supplied.) 18 USC § 2518 (8) (a). “Section 2518 (8) (a) has an explicit exclusionary remedy for noncompliance with the sealing requirement, providing that ‘(t)he presence of the seal provided for by this subsection, or a satisfactory explanation for the absence thereof, shall be a prerequisite for the use or disclosure of the contents of any wire, oral, or electronic communication or evidence derived therefrom under subsection (3) of section 2517.’ ” (Footnote omitted.) United States v. Ojeda Rios, 495 U. S. 257, 260 (110 SC 1845, 109 LE2d 224) (1990) quoting 18 USC § 2518 (8) (a). The question in the case sub judice then becomes whether the sealing of the tapes by the police, which condition is later inspected by and approved by the judge issuing the warrant is sufficient to meet the requirements of immediate judicial sealing of the tapes as prescribed by 18 USC § 2518 (8) (a).

In Ojeda Rios, the Supreme Court addressed whether tapes which bore seals should be suppressed because the seals had not been attached immediately as required by the statute. Ojeda Rios, supra, 495 U. S. at 260. Therein, the government put tapes in sealed boxes for 82 and 118-day periods prior to taking them to the Court for sealing.4 The Supreme Court emphasized that 18 USC § 2518 (8) (a) “provides that ‘the seal provided for by this subsection1 (emphasis added) is a prerequisite to the admissibility of electronic surveillance tapes. The clear import of these provisions is that the seal required by § 2518 (8) (a) is not just any seal but a seal that has been obtained immediately upon expiration of the underlying surveillance order.” 495 U. S. at 263. The Court reasoned that “the seal [was] a means of ensuring that subsequent to its placement on a tape, the Government [29]*29[had] no opportunity to tamper with, alter, or edit the conversations that [had] been recorded. It is clear . . . that Congress viewed the sealing requirement as important precisely because it limits the Government’s opportunity to alter the recordings.” Id. Thereafter, the Court concluded “that 2518 (8) (a) appliefd] to a delay in sealing, as well as to a complete failure to seal, tapes.” Id. at 264.

The state admits that the tapes were not judicially sealed until March 28, 1991; however, it argues that the tapes were “sealed”5 by the officers monitoring the surveillance recorders when the tapes were removed from the recorders. The tapes were then sealed in evidence bags and stored in a locked room with a locked steel door. The state asserts that all the requirements of § 2518 (8) (a) were met, but in reverse order, i.e., the tapes were sealed at the earliest possible moment and then made available to the court, rather than making the tapes immediately available to the court for sealing.

We do not agree that the sealing of the tapes performed by the officers can replace the immediate judicial sealing required by the statute. The purpose for having the tapes sealed immediately by the judge is to protect private citizens from the police. It follows therefore that to approve the immediate sealing of the tapes by the police, in lieu of the judge, would destroy the protective scheme established by the statute, as only the word of the police officer would be available to establish when such sealing occurred.

The officers’ “sealing” of the tapes did not strictly adhere to the statutorily prescribed procedures for the sealing of tapes containing conversations intercepted pursuant to 18 USC § 2518. The primary purpose behind the requirements contained in § 2518 (8) (a) “is to ensure the reliability and integrity of evidence obtained by means of electronic surveillance.” Ojeda Rios, supra at 263. Allowing the state to perform the sealing process and then submit it for judicial approval, whenever it is ready, presupposes the need for strict supervisory requirements. “The immediate sealing and storage of recordings of intercepted conversations under the supervision of a judge, is an integral part of [the] statutory scheme. (Emphasis supplied.) United States v. Gigante, 538 F2d 502, 505 (2d Cir. 1976). “Section 2518 (8) (a) provides for continuous judicial scrutiny of the entire process of obtaining and utilizing recorded conversations, and consequently requires their presentation to a judge ‘immediately’ — as the statute insists — upon the expiration of the authorizing order.” Id. at 506.

The state next argues that “[s]ometimes when Administrative requirements of the wiretap warrant statutes are not complied with, the [30]

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Porter v. State
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Cite This Page — Counsel Stack

Bluebook (online)
432 S.E.2d 629, 209 Ga. App. 27, 93 Fulton County D. Rep. 2485, 1993 Ga. App. LEXIS 745, Counsel Stack Legal Research, https://law.counselstack.com/opinion/porter-v-state-gactapp-1993.