Redding v. State

897 S.E.2d 801, 318 Ga. 225
CourtSupreme Court of Georgia
DecidedFebruary 6, 2024
DocketS23A1018
StatusPublished
Cited by4 cases

This text of 897 S.E.2d 801 (Redding 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
Redding v. State, 897 S.E.2d 801, 318 Ga. 225 (Ga. 2024).

Opinion

318 Ga. 225 FINAL COPY

S23A1018. REDDING v. THE STATE.

LAGRUA, Justice.

Following a 2018 jury trial, Appellant Merrick Redding was

found guilty of felony murder and aggravated assault in connection

with the death of Joseph Davis.1 In his first appeal to this Court, we

1 The crimes occurred on September 5, 2016. Redding was arrested for

Davis’s killing on September 12, 2016. On September 28, 2017, Redding filed a “Motion to Dismiss Charge Based on Violation of Constitutional Right to Speedy Trial.” On April 24, 2018, a Muscogee County grand jury indicted Redding for malice murder, felony murder, and aggravated assault with a “closed fist.” He was reindicted on the same charges on May 22, 2018. At a trial from October 24 to November 5, 2018, the jury found Redding not guilty of malice murder but guilty of the remaining counts. The trial court orally denied the speedy-trial motion at the pretrial conference and ultimately sentenced Redding to life in prison without the possibility of parole for felony murder and a concurrent term of 20 years to serve in prison for aggravated assault. Redding filed a timely motion for new trial, which the trial court denied on June 4, 2019. Redding filed a timely notice of appeal, and in Redding v. State, 309 Ga. 124 (844 SE2d 725) (2020), this Court vacated the trial court judgment and remanded with direction. On remand, the trial court merged the aggravated assault count into felony murder, resentenced Redding to serve life in prison without the possibility of parole for felony murder, and entered its first written order denying Redding’s speedy-trial motion. Redding filed a timely notice of appeal, and in Redding v. State, 313 Ga. 730 (873 SE2d 158) (2022), this Court again vacated the judgment and remanded with direction. On remand, the trial court entered a second written order denying the speedy- trial motion on March 6, 2023. Redding filed a timely notice of appeal, and the case was docketed to this Court’s August 2023 term and submitted for a decision on the briefs. held that the evidence presented at Redding’s trial was legally

sufficient to support his murder conviction, but we otherwise

vacated the judgment and remanded the case for the trial court to

make factual findings and legal conclusions regarding Redding’s

allegation of a violation of his Sixth Amendment right to a speedy

trial.2 See Redding v. State, 309 Ga. 124, 129-130 (3) (844 SE2d 725)

(2020) (“Redding I”).

On remand, the trial court issued a written order denying the

speedy-trial motion. Redding filed a second appeal, again contending

his speedy-trial rights were violated along with other claims of error.

This Court vacated the judgment and remanded the case a second

time “because the trial court misstated and misapplied the law

regarding the prejudice factor, failed to weigh each Barker factor,

and conflated its consideration of some of the factors. . . .” Redding

v. State, 313 Ga. 730, 736 (2) (873 SE2d 158) (2022) (“Redding II”).

On remand, the trial court entered a second written order

2 “In all criminal prosecutions, the accused shall enjoy the right to a

speedy and public trial.” U. S. Const. Amend. VI. 2 denying the speedy-trial motion. Redding filed his third appeal,

presently before the Court, again raising his speedy-trial claim

along with other previously unaddressed claims. For a third time,

we vacate the trial court’s order and remand this case for the trial

court to resolve the speedy-trial claim. We will not address the

remaining claims of error.

1. A constitutional speedy-trial claim is evaluated under the

two-part framework set out in Barker v. Wingo, 407 U. S. 514, 530

(IV) (92 SCt 2182, 33 LE2d 101) (1972) and Doggett v. United States,

505 U. S. 647, 652 (II) (112 SCt 2686, 120 LE2d 520) (1992). As we

explained in Redding II,

[f]irst, the trial court must consider whether the length of time between the defendant’s arrest and trial is sufficiently long to be considered presumptively prejudicial. If not, the speedy-trial claim fails at the threshold. A delay of one year or more is typically presumed to be prejudicial. In Redding I, we concluded that the presumptive-prejudice threshold was crossed in this case. When that threshold is crossed, the trial court proceeds to the second part of the framework, applying a context-focused, four-factor balancing test to determine whether the defendant was denied the right to a speedy trial. These four factors are (1) the length of the delay; (2)

3 the reasons for it; (3) the defendant’s assertion of his right to a speedy trial; and (4) prejudice to the defendant.

Redding II, 313 Ga. at 731-732 (2) (citations and punctuation

omitted). Consideration of the Barker-Doggett factors “requires

courts to engage in a difficult and sensitive balancing process,” and

the four factors have no “talismanic qualities and must be

considered together.” Leonard v. State, 316 Ga. 827, 839 (6) (889

SE2d 837) (2023) (citation and punctuation omitted).

When reviewing the trial court’s weighing and balancing of the

factors, this Court

must accept the factual findings of the trial court unless they are clearly erroneous, and we must accept the ultimate conclusion of the trial court unless it amounts to an abuse of discretion, even though we might have reached a different conclusion were the issue committed to our discretion.

Henderson v. State, 310 Ga. 231, 235 (2) (850 SE2d 152) (2020)

(citation and punctuation omitted). But in the context of a

constitutional speedy-trial analysis, if the trial court’s factual

findings are clearly erroneous or the trial court “significantly

misapplies the law,” then “the trial court’s exercise of discretion can

4 be affirmed only if the appellate court can conclude that, had the

trial court used the correct fact[ual] and legal analysis, it would have

had no discretion to reach a different judgment.” State v. Pickett, 288

Ga. 674, 679 (2) (d) (706 SE2d 561) (2011). If the trial court would

still have discretion to reach a different judgment, we remand for

the trial court to reweigh the factors and exercise its discretion using

the correct factual and legal analysis. See State v. Johnson, 291 Ga.

863, 868 (3) (734 SE2d 12) (2012).

2. Redding was arrested on September 12, 2016, indicted 19

months later on April 24, 2018, reindicted on the same charges on

May 22, 2018, and tried five months later on October 24, 2018. The

trial court properly found this cumulative 25-month period was

presumptively prejudicial — as we also concluded in Redding I —

and proceeded to consider the Barker-Doggett factors. See Redding

I, 309 Ga. at 129 (3) (holding the presumptive-prejudice threshold

was crossed in this case).

(a) The length of the delay.

The trial court erred by weighing the length-of-delay factor

5 neutrally.

The length of the pretrial delay in absolute terms plays a role in the threshold determination of presumptive prejudice. However, it also wears another hat as one of the four interrelated criteria that must be weighed in the balance at the second stage of the Barker-Doggett analysis.

Ruffin v. State, 284 Ga. 52, 56 (2) (b) (i) (663 SE2d 189) (2008)

(emphasis supplied). While similar, the presumptive prejudice

threshold and the length-of-delay factor are separate inquiries.

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

Related

Kitchens v. State
Supreme Court of Georgia, 2025
State v. Embert
Supreme Court of Georgia, 2025
Nelson v. State
915 S.E.2d 541 (Supreme Court of Georgia, 2025)
Redding v. State
907 S.E.2d 258 (Supreme Court of Georgia, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
897 S.E.2d 801, 318 Ga. 225, Counsel Stack Legal Research, https://law.counselstack.com/opinion/redding-v-state-ga-2024.