Rebecca Wiggins v. State

CourtCourt of Appeals of Georgia
DecidedJune 24, 2016
DocketA16A0162
StatusPublished

This text of Rebecca Wiggins v. State (Rebecca Wiggins 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
Rebecca Wiggins v. State, (Ga. Ct. App. 2016).

Opinion

THIRD DIVISION MILLER, P. J., MCFADDEN and MCMILLIAN, 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. http://www.gaappeals.us/rules

June 24, 2016

In the Court of Appeals of Georgia A16A0162. WIGGINS v. THE STATE.

MCMILLIAN, Judge.

Rebecca Wiggins appealed the denial of her motion for new trial after a jury

convicted her of sexual exploitation of children, aggravated sodomy, child

molestation, and cruelty to children in the first degree.1 In Wiggins v. State, 330 Ga.

App. 205, 211 (c) (767 SE2d 798) (2014) (“Wiggins I”), this Court found that

although the evidence at trial was sufficient to support Wiggins’ convictions, the

record failed to demonstrate that the trial judge applied the proper standard in

reviewing her convictions on the general grounds. Accordingly, we vacated the

judgment and remanded the case to the trial court to reconsider the issue under the

1 The child molestation and cruelty to children counts were merged with the aggravated sodomy count for sentencing. appropriate discretionary standard, and we declined to rule on Wiggins’ remaining

enumerations of error at that time. Id.

On remand, the trial court held a hearing and issued an order denying Wiggins’

motion for new trial on the general grounds. Wiggins now appeals from that order,

reasserting the enumerations of error not reached by this Court in Wiggins I and

further asserting that on remand, the trial court failed to give the proper weight to the

defense expert’s testimony in reviewing the evidence on the general grounds.2

The charges in this case arose out of allegations that sometime between

November 17, 2001 and November 16, 2003, Wiggins took sexually explicit pictures

of the victim, and sometime between February 25, 2004 and September 30, 2004, she

took the victim to David Ray’s house and was present when Ray sodomized her. We

summarized the evidence from Wiggins’ trial in Wiggins I, and we need not restate

2 To the extent that Wiggins also attempts to re-argue that the evidence at trial was insufficient to support her convictions, any such argument is barred by our prior ruling in Wiggins I, and we will not consider it. See OCGA § 9-11-60 (h)(“[A]ny ruling by the Supreme Court or the Court of Appeals in a case shall be binding in all subsequent proceedings in that case in the lower court and in the Supreme Court or the Court of Appeals as the case may be.”); Pierce v. State, 278 Ga. App. 162, 163 (1) (628 SE2d 235) (2006) (“This law of the case rule is not confined to civil cases, but applies also to rulings made by appellate courts in criminal cases.”) (citation omitted). See also Roulain v. Martin, 266 Ga. 353, 354 (466 SE2d 837) (1996).

2 the evidence here. However, we note that the victim3 testified that on a number of

occasions, Wiggins took her to Ray’s house, bathed her in a bathtub, took her to the

room where Ray was waiting, stayed in the room while Ray sexually assaulted her,

and then accepted payment from Ray afterwards.4

1. In her first enumeration, Wiggins asserts that the trial court erred in denying

her motion in limine to prevent testimony and evidence showing that she had been a

victim of molestation when she was a child.

Wiggins’ trial counsel (“Defense Counsel”) made an oral motion in limine at

trial to exclude any evidence alleging that Wiggins was the prior victim of sexual

assault after the prosecution stated that it wanted to elicit evidence that Wiggins told

the victim that she had been molested by her father when she was a child. Defense

Counsel argued that such evidence placed her client’s character into evidence, was

highly prejudicial, and was hearsay. The prosecutor argued, however, that the

evidence was not hearsay because it was a statement made by Wiggins as a part of the

3 The victim was 11 years old at the time she first made the allegations against Ray in this case. Wiggins I, 330 Ga. App. at 207. 4 We note that Ray committed suicide on April 4, 2009 after police executed a search warrant on his home in connection with the victim’s allegations, Wiggins I, 330 Ga. App. at 208, and thus he was not tried in connection with these crimes.

3 crime and that the evidence was admissible because it went to the issues of Wiggins’

intent, knowledge, and motive.

The trial court denied the motion in limine, and the victim later testified that

when Wiggins took her to Ray’s house, she would talk to her about “what happened

to her when she was little, like what her dad molested her with and things like that.”

The victim said that Wiggins told her that she was telling her these things “[t]o make

me feel comfortable, to make me feel like it was right to do, right for me to do what

he was doing to me.” Melissa Dotterweich, the State’s expert witness,5 a therapist

who worked with the victim, testified that during their sessions, the victim went into

detail about what Wiggins had told her, including that her father had molested her

when she was young. Defense Counsel renewed her prior objections to this evidence,

but the trial court overruled them.

Generally, appellate courts review a trial court’s decision on the admission of

evidence for an abuse of discretion. See Moore v. State, 295 Ga. 709, 712 (2) (763

SE2d 670) (2014). And “[w]here[, as here,] the evidence at a hearing on a motion in

limine is uncontroverted, and no issue exists regarding the credibility of witnesses,

5 The trial court qualified Dotterweich as an expert “in the field of child sexual abuse and the disclosure process,” including forensic interviewing.

4 we review the trial court’s ruling to ensure that there was a substantial basis for it.

The trial court’s application of the law to the undisputed facts is subject to de novo

review.” (Citation omitted.) State v. Barnard, 321 Ga. App. 20, 20 (740 SE2d 837)

(2013).

The evidence at issue concerned statements made by Wiggins as she took the

victim to Ray’s house where he performed sexual acts upon the child. Former OCGA

§ 24-3-3, which was applicable at the time of Wiggins’ trial,6 provided that

“[d]eclarations accompanying an act, or so nearly connected therewith in time as to

be free from all suspicion of device or afterthought, shall be admissible in evidence

as part of the res gestae.” And “[u]nder longstanding Georgia law, all the acts and

circumstances surrounding and constituting the res gestae are admissible, despite the

fact that they may reflect poorly on a defendant’s character.” Baughns v. State, 335

Ga. App. 600, 602 (1) (782 SE2d 494) (2016). Therefore, “evidence of statements

made by the defendant during the commission of the offense is admissible as part of

the res gestae of the crime even if it puts the defendant’s character in evidence.” Ware

v. State, 308 Ga. App. 24, 28 (3) (707 SE2d 111) (2011). Accordingly, pretermitting

6 Because the trial in this case was held before January 1, 2013, we apply Georgia’s old Evidence Code to the evidentiary issues raised on appeal. See Bragg v. State, 295 Ga. 676, 677 (2), n.3 (763 SE2d 476) (2014).

5 whether evidence showing that the defendant was herself previously the victim of a

sexual crime may be considered evidence of bad character, we find that Wiggins’

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

Related

Berger v. United States
295 U.S. 78 (Supreme Court, 1935)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
Pierce v. State
628 S.E.2d 235 (Court of Appeals of Georgia, 2006)
Frazier v. State
467 S.E.2d 338 (Court of Appeals of Georgia, 1995)
Whitehead v. State
438 S.E.2d 128 (Court of Appeals of Georgia, 1993)
Johnson v. State
503 S.E.2d 603 (Court of Appeals of Georgia, 1998)
State v. Heath
588 S.E.2d 738 (Supreme Court of Georgia, 2003)
Brownlow v. State
544 S.E.2d 472 (Court of Appeals of Georgia, 2001)
Gentry v. State
201 S.E.2d 679 (Court of Appeals of Georgia, 1973)
Jordan v. State
480 S.E.2d 18 (Supreme Court of Georgia, 1997)
Conyers v. State
291 S.E.2d 709 (Supreme Court of Georgia, 1982)
Byron v. State
495 S.E.2d 123 (Court of Appeals of Georgia, 1997)
Lloyd v. State
373 S.E.2d 1 (Supreme Court of Georgia, 1988)
Brown v. State
404 S.E.2d 469 (Court of Appeals of Georgia, 1991)
Medlock v. State
430 S.E.2d 754 (Supreme Court of Georgia, 1993)
Henry v. State
507 S.E.2d 419 (Supreme Court of Georgia, 1998)
Branesky v. State
584 S.E.2d 669 (Court of Appeals of Georgia, 2003)
Roulain v. Martin
466 S.E.2d 837 (Supreme Court of Georgia, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
Rebecca Wiggins v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rebecca-wiggins-v-state-gactapp-2016.