State v. Kristen Ann Hammonds

CourtCourt of Appeals of Georgia
DecidedFebruary 24, 2014
DocketA13A2023
StatusPublished

This text of State v. Kristen Ann Hammonds (State v. Kristen Ann Hammonds) 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. Kristen Ann Hammonds, (Ga. Ct. App. 2014).

Opinion

SECOND DIVISION BARNES, P. J., MILLER and RAY, 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/

February 24, 2014

In the Court of Appeals of Georgia A13A2023. THE STATE v. HAMMONDS.

RAY, Judge.

The State appeals the trial court’s grant of Kristen Ann Hammonds’s motion

to dismiss and quash the indictment, such indictment which charged Hammonds with

six counts of sexual assault against a person in custody in violation of OCGA § 16-6-

5.1 (b) (1). For the reasons that follow, we affirm.

“We begin by noting that the interpretation of a statute is a question of law,

which is reviewed de novo on appeal. Because the trial court’s ruling on a legal

question is not due any deference, we apply the ‘plain legal error’ standard of

review.” (Citation and punctuation omitted.) Frix v. State, 298 Ga. App. 538, 539

(680 SE2d 582) (2009).

OCGA § 16-6-5.1 (b) (1) provides in relevant part: A person who has supervisory or disciplinary authority over another individual commits sexual assault when that person . . . [i]s a teacher, principal, assistant principal, or other administrator of any school and engages in sexual contact with such other individual who the actor knew or should have known is enrolled at the same school . . . .

Hammonds’s indictment alleged that she engaged in sexual contact with three

males that she knew were students at the high school where she was employed as an

“administrator” with supervisory or disciplinary authority over the students. The

record shows that Hammonds was a secretary at the school’s ninth grade academy,

as well as an assistant coach for the junior varsity cheerleading team. The three male

students involved were between the ages of 17 and 19 years old. One was a junior and

the other two were seniors, and they were not members of the cheerleading team. The

sole issue in this case is whether Hammonds, as a secretary and an assistant

cheerleading coach, is among the classification of individuals with supervisory or

disciplinary authority subject to prosecution under OCGA § 16-6-5.1 (b) (1).

At the hearing on the motion to dismiss and quash the indictment, the school’s

principal testified that Hammonds’s job duties as a secretary were limited to

answering the telephone and performing general office and clerical work. She had no

disciplinary authority over any of the students, and if she observed any misconduct

2 on the part of a student, she could only report it to one of the administrators.

Although she had the authority to write up disciplinary referrals, the principal

testified that “everybody on campus [had] the [authority] to do that.”1 The principal

further testified that Hammonds had no supervisory authority over any students

beyond the basic supervision that “[any] adult in the building” would have.2

The trial court granted the motion to dismiss the indictment, finding that

Hammonds did not fall within the ambit of OCGA § 16-6-5.1 (b) (1). Specifically, the

trial court found that Hammonds was not a teacher, a principal, an assistant principal,

or an administrator at the school, and that she lacked the requisite disciplinary and

supervisory authority over the students. The trial court further found that Hammonds,

in her capacity as an assistant cheerleading coach, was not in a position of authority

over the three students with whom she was sexually involved.

In the construction of statutes, the courts shall look diligently for the intention of the General Assembly. In so doing, the ordinary

1 If Hammonds was considered an administrator simply because she could initiate a disciplinary referral, then logically an argument can be made that the same would apply to janitors or food service workers. 2 At the hearing, Hammonds and the State stipulated that one of the students involved would testify that he perceived Hammonds to be an authority figure at the school.

3 signification shall be applied to all words. Where the language of a statute is plain and susceptible to only one natural and reasonable construction, courts must construe the statute accordingly.

(Citation omitted.) Luangkhot v. State, 292 Ga. 423, 424 (1) (736 SE2d 397) (2013).

Furthermore, “[i]t is an elementary rule of statutory construction that, absent clear

evidence to the contrary, words should be assigned their ordinary, logical, and

common meaning.” (Citation and punctuation omitted.) Belvin v. State, 221 Ga. App.

114, 115 (470 SE2d 497) (1996).

According to the Merriam-Webster online dictionary,3 an “administrator” is

defined as “a person whose job is to manage a company, school, or other

organization” or “one who administers especially business, school, or governmental

affairs.”4 The same resource defines a “secretary” as “a person whose job is to handle

records, letters, etc., for another person in an office” or “one employed to handle

correspondence and manage routine and detail work for a superior.”5

3 Merriam-Webster.com. Merriam-Webster, n. d. Web. 31 January 2014. 4 See http://www.merriam-webster.com/dictionary/administrator. 5 See http://www.merriam-webster.com/dictionary/secretary.

4 Here, the record shows that Hammonds’s job as a secretary at the school was

strictly clerical in nature and, as such, did not fall within the ordinary, logical, and

common definition of an “administrator.” If we were to hold that a secretary is

equivalent to an administrator, we would be judicially expanding the term

“administrator” beyond its ordinary, logical, and common meaning for the purposes

of OCGA § 16-6-5.1 (b) (1) . This we cannot do. “[C]ourts must generally refrain

from expanding the scope of penal statutes by implication[.]” (Citation and

punctuation omitted.) Belvin, supra. Compare Hart v. State, 319 Ga. App. 749, 750-

751 (738 SE2d 331) (2013) (Interpretation of the term “teacher” in OCGA § 16-6-5.1

(b) (1) to include a “paraprofessional” who taught in a high school classroom did not

constitute an impermissible judicial expansion of term “teacher” beyond its ordinary,

logical, and common meaning). Under the facts and circumstances of this case, we

find that Hammonds, in her secretarial position, was not an “administrator” for the

purposes of prosecution under OCGA § 16-6-5.1 (b) (1).

The State also argues that Hammonds could be considered a “teacher” for the

purposes of OCGA § 16-6-5.1 (b) (1) because she was an assistant cheerleading

coach who helped “teach” cheerleading. We find this argument to be unpersuasive.

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Related

Belvin v. State
470 S.E.2d 497 (Court of Appeals of Georgia, 1996)
Frix v. State
680 S.E.2d 582 (Court of Appeals of Georgia, 2009)
Whitehead v. State
672 S.E.2d 517 (Court of Appeals of Georgia, 2009)
Hedden v. State
708 S.E.2d 287 (Supreme Court of Georgia, 2011)
Luangkhot v. State
736 S.E.2d 397 (Supreme Court of Georgia, 2013)
Hart v. State
738 S.E.2d 331 (Court of Appeals of Georgia, 2013)

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State v. Kristen Ann Hammonds, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kristen-ann-hammonds-gactapp-2014.