State v. Eugene Hartsfield

CourtCourt of Appeals of Georgia
DecidedNovember 20, 2012
DocketA12A1102
StatusPublished

This text of State v. Eugene Hartsfield (State v. Eugene Hartsfield) 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. Eugene Hartsfield, (Ga. Ct. App. 2012).

Opinion

THIRD DIVISION MILLER, P. J., RAY and BRANCH, 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. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

November 20, 2012

In the Court of Appeals of Georgia A12A1102. THE STATE v. HARTSFIELD.

B RANCH, Judge.

The State previously appealed the trial court’s grant of Eugene Hartsfield’s

motion to dismiss his indictment for violation of his constitutional right to a speedy

trial. On review, we vacated the trial court’s order and remanded the case for

reconsideration because some of the trial court’s findings of fact were not supported

by the record and because the court made other errors. State v. Hartsfield, 308 Ga.

App. 753, 754-755 (1) (711 SE2d 1) (2011). Upon remand, the trial court reconvened

the hearing and received further evidence from Hartsfield; the State offered no

evidence. The court again granted Hartsfield’s motion to dismiss, and the State again

appeals. The procedural facts set out in the prior appeal show the lengthy passage of

time in this case:

Hartsfield was arrested on April 16, 2005. He was indicted on April 14, 2009, for aggravated battery, aggravated assault, and three counts of violation of oath by a public officer. The case was placed on a trial calendar in July 2010, but on July 30, 2010, Hartsfield filed a motion to dismiss the indictment for violation of his right to a speedy trial under the state and federal constitutions. The trial court granted the motion on August 6, 2010, and the state filed this [first] appeal.

Id. at 753. After this court vacated the trial court’s order and remanded the case, the

trial court held the second hearing on October 5, 2011 , and it granted Hartsfield’s

speedy trial motion anew on January 4, 2012.

As noted in the earlier appeal, constitutional speedy trial claims are governed

by the framework laid out in Barker v. Wingo, 407 U. S. 514 (92 SC 2182, 33 LE2d

101) (1972), and Doggett v. United States, 505 U. S. 647 (112 SC 2686, 120 LE2d

520) (1992). Ruffin v. State, 284 Ga. 52, 55 (2) (663 SE2d 189) (2008). The analysis

has two stages:

In the first stage of the analysis, the court must determine whether the pretrial delay is sufficiently long to be considered presumptively prejudicial. . . . If the delay has passed the point of presumptive prejudice, the court must proceed to the second step of the Barker-

2 Doggett analysis, which requires the application of a delicate, context-sensitive, four-factor balancing test to determine whether the accused has been deprived of the right to a speedy trial.

(Citations, punctuation and footnote omitted.) Ferguson v. State, 303 Ga. App. 341,

342 (693 SE2d 578) (2010). “The four factors to be considered in the case of

presumptively prejudicial delay are (a) the length of the delay, (b) the reason for the

delay, (c) the defendant’s assertion of his right, and (d) the prejudice to the

defendant.” (Citation omitted.) Hartsfield, 308 Ga. App. at 753 (1).

We must determine whether the trial court abused its broad discretion in ruling

that Hartsfield’s speedy trial rights were violated. State v. Gleaton, 288 Ga. 373, 375

(703 SE2d 642) (2010). Nevertheless, “where. . . the trial court has clearly erred in

some of its findings of fact and/or has misapplied the law to some degree, the

deference owed the trial court’s ultimate ruling is diminished.” Williams v. State, 277

Ga. 598 (1) (e) (592 SE2d 848) (2004).

(a) As in the earlier appeal, the State concedes and the trial court properly found

that the 48-month delay from Hartsfield’s arrest to his indictment plus the subsequent

15-month delay prior to Hartsfield’s initial motion to dismiss was presumptively

prejudicial.

3 (b) Given that the threshold inquiry has been met, the trial court must again

consider the length of the delay:

[T]he length of the delay should be considered by the trial court again “by factoring it into the prejudice prong of the Barker analysis, with the presumption that pretrial delay has prejudiced the accused intensifying over time.” The presumptive prejudice arising from the delay is “part of the mix of relevant facts, and its importance increases with the length of delay,” but it “cannot alone carry a Sixth Amendment claim without regard to the other Barker criteria.”

(Footnotes omitted.) Harris v. State, 314 Ga. App. 565, 566 (b) (i) (724 SE2d 864)

(2012).

The State concedes the trial court correctly weighed the length of the delay in

favor of Hartsfield, and we agree. The delay here was uncommonly long given that

the case involves only one brief incident between two people: Hartsfield, a P.O.S.T.

certified1 officer and an employee of the Georgia Department of Juvenile Justice, who

was working an approved second job providing security for a nightclub; and a patron

1 The Georgia Peace Officer Standards and Training Act, OCGA § 35-8-1 et seq., establishes the Georgia Peace Officers’ Standards and Training Council (P.O.S.T.), and that entity determines whether a candidate “is qualified to be employed as a peace officer” and “issues a certificate to those so qualified.” OCGA § 35-8-7 (12).

4 of that nightclub. Hartsfield was charged with aggravated battery, aggravated assault,

and three counts of violation of an oath by a public officer for allegedly hitting the

patron with a flashlight.

(c) The first contention on appeal is that the trial court, for the second time,

erred in its analysis of the second factor – the reason for the delay. In the first appeal,

we found that the trial court erred in concluding that the reason for the delay was “far

from benign.” Hartsfield, 308 Ga. App. at 754-755 (1) (c). In its order upon remand,

the court noted that despite a second hearing regarding the matter, “[t]he State elected

at the original hearing, and at the hearing reconvened on remand, to present no

explanation whatsoever” for the reason for the four-year delay in indicting Hartsfield.

The court emphasized that “the State [ ] stood mute and offered no explanation for the

reason for the preindictment delay.” The court offered its interpretation of the State’s

position:

The Court construes this silence as, at best, an admission that there is no explanation for the delay, or, at worst, a desire to avoid acknowledging a more egregious reason for delay (such as hampering the defense or harassing the Defendant).

Finally, the court noted that it was independently aware of another case “in which the

State unduly delayed indictment of a P.O.S.T. certified officer.”

5 The court then considered evidence offered by Hartsfield suggesting that the

State had no just reason for delaying the indictment. In so doing, the court found that

the District Attorney’s investigation was mostly complete after June 2005, which

finding is supported by the record. The court commented on the straightforward nature

of the case, arising from what the court termed “a barroom brawl.” The court also

noted that there were no other factors that would add layers of complexity.

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Related

Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
Vermont v. Brillon
556 U.S. 81 (Supreme Court, 2009)
Jackson v. State
534 S.E.2d 796 (Supreme Court of Georgia, 2000)
Boseman v. State
438 S.E.2d 626 (Supreme Court of Georgia, 1994)
Ditman v. State
687 S.E.2d 155 (Court of Appeals of Georgia, 2009)
Hayes v. State
680 S.E.2d 182 (Court of Appeals of Georgia, 2009)
Brannen v. State
553 S.E.2d 813 (Supreme Court of Georgia, 2001)
Williams v. State
592 S.E.2d 848 (Supreme Court of Georgia, 2004)
Ferguson v. State
693 S.E.2d 578 (Court of Appeals of Georgia, 2010)
Lambert v. State
692 S.E.2d 15 (Court of Appeals of Georgia, 2010)
Watkins v. State
600 S.E.2d 747 (Court of Appeals of Georgia, 2004)
Sweatman v. State
700 S.E.2d 579 (Supreme Court of Georgia, 2010)
State v. Pickett
706 S.E.2d 561 (Supreme Court of Georgia, 2011)
State v. Porter
705 S.E.2d 636 (Supreme Court of Georgia, 2011)
State v. Gleaton
703 S.E.2d 642 (Supreme Court of Georgia, 2010)
State v. Shirley
714 S.E.2d 636 (Court of Appeals of Georgia, 2011)
Williams v. State
717 S.E.2d 640 (Supreme Court of Georgia, 2011)
State v. Reimers
714 S.E.2d 417 (Court of Appeals of Georgia, 2011)
Weems v. State
714 S.E.2d 119 (Court of Appeals of Georgia, 2011)

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