State v. Bayley Almeida

CourtCourt of Appeals of Georgia
DecidedFebruary 27, 2025
DocketA24A1733
StatusPublished

This text of State v. Bayley Almeida (State v. Bayley Almeida) 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
State v. Bayley Almeida, (Ga. Ct. App. 2025).

Opinion

THIRD DIVISION DOYLE, P. J., HODGES and WATKINS, 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. https://www.gaappeals.us/rules

February 27, 2025

In the Court of Appeals of Georgia A24A1733. THE STATE v. ALMEIDA, et al.

DOYLE, Presiding Judge.

The State appeals from the grant of a motion to suppress evidence it seeks to

use to prosecute Bayley Almeida for one count of misdemeanor obstruction of an

officer.1 The State contends that the trial court erred by ruling that her arrest arose

from an unlawful entry into her residence without a warrant or exigent circumstances.

Because the record shows that the State failed to meet its burden to show exigency,

and the subsequent arrest arose from that entry and Almeida’s refusal to consent to

a re-entry into her residence, we affirm the grant of Almeida’s motion to suppress.

1 See OCGA § 5-7-1 (a) (4) (authorizing the State to appeal from an order suppressing evidence in a criminal prosecution). First, when a motion to suppress is heard by the trial judge, that judge sits as the trier of facts. The trial judge hears the evidence, and his findings based upon conflicting evidence are analogous to the verdict of a jury and should not be disturbed by a reviewing court if there is any evidence to support them. Second, the trial court’s decision with regard to questions of fact and credibility must be accepted unless clearly erroneous. Third, the reviewing court must construe the evidence most favorably to the upholding of the trial court’s findings and judgment. On numerous occasions the appellate courts of this state have invoked these three principles to affirm trial court rulings that upheld the validity of seizures. These same principles of law apply equally to trial court rulings that are in favor of the defendant. . . .[T]his standard of review requires us to focus on the findings of fact made by the trial court in its order and the evidence supporting those findings, rather than other evidence gleaned from the record, construing it in favor of upholding the trial court’s order.2

Further, the relevant events were captured in the arresting officer’s body cam footage,

and “to the extent that the controlling facts ‘are undisputed because they are plainly

discernable from the [police] video recording,’ . . . we review those facts de novo.”3

2 (Citations and punctuation omitted.) State v. Rosenbaum, 305 Ga. 442, 449 (2) (826 SE2d 18) (2019). 3 (Punctuation omitted.) State v. Depol, 336 Ga. App. 191, 191 (784 SE2d 51) (2016). See also Licata v. State, 305 Ga. 498, 500 (1), n. 2 (826 SE2d 94) (2019) (“Although we typically defer to the trial court’s factual findings in this context, 2 So viewed, the evidence from the suppression hearing shows that at

approximately 10:20 p.m. one evening in September 2020, a sheriff’s deputy

responded to a call regarding a “domestic issue” at a residence. The call was based

on a neighbor complaining that the residents “were out in the yard breaking windows

and fighting.” The deputy responded to the residence without lights and sirens so that

he could “listen for arguing, fighting, [or] shooting. . . .” After pausing along the side

of the house to listen for noise, the deputy walked to the front porch, testifying that

“[i]t sounded like two or three people arguing or fighting and some shuffling around

in the back bedroom.” As the deputy approached to knock on the front door, an

occupant emerged at the same time whom the deputy recognized as having an

outstanding warrant for a shoplifting offense. The deputy asked the occupant his

name, and as they spoke briefly, the deputy heard some yelling coming from the back

part of the house.

The occupant was calm and not evasive; he explained that he did not live there,

but he objected to the deputy entering the house. He offered to go get someone who

lived there, and explained that everything “was ok,” and “they’re fine,” but at that

when, as here, the controlling facts are not in dispute, because they are discernible from a video, our review is de novo.”). 3 point, the deputy pushed the door open and walked in, explaining, “if they’re yelling

and fighting I want to make sure everything’s ok.” The occupant countered,

“nobody’s fighting,” as the deputy walked past him into the living room.

At that point, the deputy announced, “hey there, sheriff’s office,” and he was

met by two occupants who immediately objected to the deputy’s presence, asked him

to leave, and stated that “nobody’s arguing.” The two occupants repeatedly objected

to the deputy’s presence, stating, “you need to exit the property, you have no

warrant.” The deputy responded by saying “alright, come outside with me.” The

occupants replied, “no, you’re going outside,” at which point Almeida appeared from

the back of the house and accompanied the deputy onto the front porch and closed the

door behind her.

Almeida calmly stood on the porch facing the deputy with her back to the door

and answered the deputy’s questions. She asked the deputy why he was there and

explained that it was just family in the house and that the arguing the deputy heard

was “not like that.” She further explained that someone had a pre-existing wound on

his hand that had re-opened and that they were trying to treat the wound. The deputy

asked whether it was from a reported broken window, and Almeida explained that it

4 was not. The deputy stated that he needed to “go in to make sure he’s ok,” and

Almeida replied, “no, not without a warrant.” The deputy responded, “You can

either allow me to do that, or I’m placing you under arrest.” Almeida responded, “I

guess you’re placing me under arrest.” The deputy then took Alemeida by the arm

and told her to step out of the way as he moved her away from the door; Almeida

offered no resistence and said, “that’s fine, put me under arrest.” The deputy told her

to have a seat in a chair on the porch, and she stood calmly reiterating her objection

to him entering the house, “that’s breaking the law,” and the deputy then stated,

“I’m arresting you for obstruction.” He placed her in handcuffs, and Almeida again

said, “that’s fine.” Almeida continued to cooperate fully with the arresting deputy as

he walked her to his vehicle, placed her in the back seat, and closed the door.

After arresting Almeida, the deputy, along with another deputy who had arrived

on the scene, entered the house over the verbal objection of two other occupants who

had appeared at the door. In the living room, the deputies encountered the injured

occupant, an adult male, who explained that he was cleaning the small wound on his

hand. He was not distraught or seeking aid, and he asked the deputies to go outside

as he attempted to calm the remaining occupants, who were escalating their demands

5 that the deputies leave the residence. At this point, it was plain that no occupants

needed or sought medical aid, and the only dispute was between the deputies and the

objecting occupants of the house.4

Based on these events, Almeida was charged with a single count of

misdemeanor obstruction.5 She moved to suppress “any evidence and statements

gathered as a result of the unlawful” entry into the home, including any evidence

relating to her arrest.

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Related

Steagald v. United States
451 U.S. 204 (Supreme Court, 1981)
Carranza v. State
467 S.E.2d 315 (Supreme Court of Georgia, 1996)
Cuaresma v. State
663 S.E.2d 396 (Court of Appeals of Georgia, 2008)
Jackson v. State
634 S.E.2d 846 (Court of Appeals of Georgia, 2006)
Richards v. State
649 S.E.2d 747 (Court of Appeals of Georgia, 2007)
State v. Ealum
643 S.E.2d 262 (Court of Appeals of Georgia, 2007)
Love v. State
659 S.E.2d 835 (Court of Appeals of Georgia, 2008)
State v. Culpepper
672 S.E.2d 494 (Court of Appeals of Georgia, 2009)
Felix v. State
523 S.E.2d 1 (Supreme Court of Georgia, 1999)
Daniel v. State
692 S.E.2d 682 (Court of Appeals of Georgia, 2010)
State v. Driggers
702 S.E.2d 925 (Court of Appeals of Georgia, 2010)
Staib v. State
711 S.E.2d 362 (Court of Appeals of Georgia, 2011)
The State v. Depol
784 S.E.2d 51 (Court of Appeals of Georgia, 2016)
The State v. Holtzclaw
802 S.E.2d 254 (Court of Appeals of Georgia, 2017)
Hourin v. State
804 S.E.2d 388 (Supreme Court of Georgia, 2017)
State v. Rosenbaum
826 S.E.2d 18 (Supreme Court of Georgia, 2019)
Licata v. State
826 S.E.2d 94 (Supreme Court of Georgia, 2019)

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Bluebook (online)
State v. Bayley Almeida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bayley-almeida-gactapp-2025.