Robert Fowler v. State

CourtCourt of Appeals of Georgia
DecidedJanuary 28, 2025
DocketA24A1407
StatusPublished

This text of Robert Fowler v. State (Robert Fowler 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
Robert Fowler v. State, (Ga. Ct. App. 2025).

Opinion

FIFTH DIVISION MERCIER, C. J., MCFADDEN, P. J., and RICKMAN, P. 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. https://www.gaappeals.us/rules

January 28, 2025

In the Court of Appeals of Georgia A24A1407. FOWLER v. THE STATE.

MCFADDEN, Presiding Judge.

After a jury trial, Robert Fowler was convicted of trafficking in

methamphetamine and fleeing from a police officer. Fowler appeals, claiming that the

trial court erred in its jury instruction on the offense of trafficking; but Fowler did not

object to the jury instruction and has failed to show that it constituted plain error. He

also claims his trial counsel was ineffective in failing to file a motion to suppress; but

Fowler has not shown that counsel’s performance was both deficient and prejudicial.

So we affirm.

1. Jury charge on trafficking The trial court instructed the jury that “[a]ny person who sells, delivers or has

possession of 28 grams or more of methamphetamine or any mixture containing

methamphetamine commits the offense of trafficking in methamphetamine.”

(Emphasis supplied). See OCGA § 16-13-31 (e) (“any person who sells, delivers, or

brings into this state or has possession of 28 grams or more of methamphetamine . .

. or any mixture containing . . . methamphetamine . . . commits the felony offense of

trafficking in methamphetamine”). Fowler contends that this instruction mandates

a new trial because it listed statutory methods of committing the offense — selling or

delivering the drug – that were not alleged in the indictment, which charged Fowler

with having possession of more than 28 grams of methamphetamine.

As Fowler concedes, because he did not object to this jury instruction at trial,

it is reviewed under the plain error standard. See OCGA § 17-8-58 (b). Under that

standard, Fowler must show, among other things, that there was a clear legal error that

affected his “substantial rights, which in the ordinary case means he must

demonstrate that it affected the outcome of the trial court proceedings.” Burley v.

State, 316 Ga. 796, 803 (888 SE2d 507) (2023) (citation and punctuation omitted).

Fowler has failed to make such a showing because “it is unlikely that the [alleged]

2 error in the instruction affected the outcome of the proceedings.” Moore v. State, 354

Ga. App. 145, 149 (2) (840 SE2d 519) (2020).

Where the indictment charges [that] a defendant committed an offense by one method, it is reversible error for the court to instruct the jury that the offense could be committed by other statutory methods with no limiting instruction. The defect is cured, however, where the court provides the jury with the indictment and instructs jurors that the burden of proof rests upon the [s]tate to prove every material allegation of the indictment and every essential element of the crime charged beyond a reasonable doubt.

Moore, supra (citation and punctuation omitted).

Here, the trial court read the indictment to the jury, instructed the jury that the

state must prove the essential elements of the crimes as charged in the indictment

beyond a reasonable doubt, and provided the indictment to the jury for deliberations.

Under these circumstances, “we discern no reasonable possibility that the jury was

misled and found [Fowler] guilty of [trafficking in methamphetamine] in a manner not

alleged in the indictment.” Rowland v. State, 349 Ga. App. 650, 654-655 (4) (825 SE2d

231) (2019) (citation and punctuation omitted). Fowler thus has not shown that the

jury instruction on trafficking amounted to plain error mandating a new trial. See

Stokes v. State, 355 Ga. App. 565, 568 (1) (a) (845 SE2d 305) (2020) (“any error [in

giving entire statutory definition of a crime] is not harmful if the trial judge confined

3 the elements of the crime to those charged in the indictment”) (citation and

punctuation omitted).

2. Ineffective assistance of counsel

Fowler claims that his trial counsel was ineffective in failing to file a motion to

suppress evidence seized from his vehicle after a high-speed chase by officers

attempting to stop him for traffic violations. To prevail on this claim, Fowler “must

show [that] counsel’s performance was deficient and that the deficient performance

so prejudiced him that there is a reasonable likelihood that, but for counsel’s errors,

the outcome of the trial would have been different.” Anderson v. State, 371 Ga. App.

139, 141 (2) (899 SE2d 770) (2024) (citation and punctuation omitted). Fowler has

failed to show both deficient performance and prejudice.

“[T]he failure to file a motion to suppress does not constitute per se ineffective

assistance of counsel[.]” Stanley v. State, 283 Ga. 36, 39 (2) (a) (656 SE2d 806)

(2008). Rather, “[w]hen the ineffective assistance of counsel claim is based on failure

to file a motion [to suppress], the defendant must make a ‘strong showing’ that the

evidence would have been suppressed had a motion to suppress been filed.” Dent v.

State, 303 Ga. 110, 118 (4) (a) (810 SE2d 527) (2018) (citation and punctuation

4 omitted). Fowler has “not [made] the requisite strong showing.” Roberts v. State, 263

Ga. 807, 810 (2) (e) (439 SE2d 911) (1994).

Fowler first argues that his trial counsel should have filed a motion to suppress

on the ground that officers conducted an invalid pretextual inventory of his vehicle at

the scene of the traffic stop and arrest. But “our courts have held that an inventory

may be conducted at the scene of arrest or at the police station.” Capellan v. State, 316

Ga. App. 467, 469 (729 SE2d 602) (2012). Moreover, “inventories conducted by the

police pursuant to standard police procedures are deemed to be reasonable under the

Fourth Amendment.” Davis v. State, 331 Ga. App. 171, 174 (769 SE2d 183) (2015)

(citation and punctuation omitted). Accord State v. Loechinger, 357 Ga. App. 852, 856

(2) (851 SE2d 838) (2020). Fowler presented no evidence at the motion for new trial

hearing showing that the inventory search in this case was not conducted pursuant to

standard police procedures. On the contrary, the officer whom Fowler called as a

witness at the hearing testified that it was standard policy for a vehicle involved in a

high-speed chase to be impounded and inventoried, that Fowler’s vehicle was

inventoried pursuant to that policy, and that officers followed the standard procedure

of completing an inventory form to document what was found in the vehicle. “Since

5 [Fowler] has not shown that his Fourth Amendment rights were violated [by an

invalid inventory], he cannot establish [the requisite strong showing] that a motion to

suppress would have been granted if one had been filed [on this ground].” State v.

Shelton, 329 Ga. App. 582, 586 (1) (a) (765 SE2d 732) (2014).

Fowler also argues that his attorney should have filed a motion to suppress on

the ground that impoundment of his vehicle was unnecessary because there was a

passenger in his truck who could have driven the vehicle away from the scene. Indeed,

“[w]hen the driver of a motor vehicle is arrested and a reliable friend is present,

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Related

Stanley v. State
656 S.E.2d 806 (Supreme Court of Georgia, 2008)
Ector v. State
681 S.E.2d 654 (Court of Appeals of Georgia, 2009)
Roberts v. State
439 S.E.2d 911 (Supreme Court of Georgia, 1994)
Teal v. State
647 S.E.2d 15 (Supreme Court of Georgia, 2007)
Fortson v. State
412 S.E.2d 833 (Supreme Court of Georgia, 1992)
The State v. Shelton
765 S.E.2d 732 (Court of Appeals of Georgia, 2014)
Davis v. the State
769 S.E.2d 183 (Court of Appeals of Georgia, 2015)
ROWLAND v. the STATE.
825 S.E.2d 231 (Court of Appeals of Georgia, 2019)
Moore v. State
748 S.E.2d 419 (Supreme Court of Georgia, 2013)
Dent v. State
810 S.E.2d 527 (Supreme Court of Georgia, 2018)
Capellan v. State
729 S.E.2d 602 (Court of Appeals of Georgia, 2012)
Dent v. State
303 Ga. 110 (Supreme Court of Georgia, 2018)
Burley v. State
888 S.E.2d 507 (Supreme Court of Georgia, 2023)

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Bluebook (online)
Robert Fowler v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-fowler-v-state-gactapp-2025.