State v. Randall

897 S.E.2d 444, 318 Ga. 79
CourtSupreme Court of Georgia
DecidedJanuary 17, 2024
DocketS23A1118
StatusPublished
Cited by9 cases

This text of 897 S.E.2d 444 (State v. Randall) 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
State v. Randall, 897 S.E.2d 444, 318 Ga. 79 (Ga. 2024).

Opinion

318 Ga. 79 FINAL COPY

S23A1118. THE STATE v. RANDALL.

BETHEL, Justice.

This criminal appeal — brought by the State1 from the grant of

Antonio Rodrick Randall’s motion to suppress evidence of his refusal

to submit to a blood test after his arrest for driving under the

influence — is the second appearance of this case before this Court.

In State v. Randall, 315 Ga. 198 (880 SE2d 134) (2022) (“Randall

I”), this Court vacated the trial court’s order suppressing the same

evidence at issue in this case based on our conclusion that the court

unnecessarily resolved Randall’s constitutional challenge to the

admissibility of blood test refusal evidence and to OCGA § 40-5-67.1

(b). 315 Ga. at 200-202 (1), (2). On remand, the trial court again

suppressed evidence of Randall’s refusal to consent to a blood test

on constitutional grounds, a ruling that the State again disputes.

However, we need not determine the correctness of that ruling,

1 See OCGA § 5-7-1 (a) (5). at least at this point in the case, because the trial court first should

have evaluated Randall’s argument that exclusion of the evidence

was warranted under OCGA § 24-4-403 (“Rule 403”) before reaching

his constitutional claims. Accordingly, we vacate the trial court’s

order on Randall’s motion to suppress and remand the case for

proceedings consistent with this opinion.

1. Case history.

We recounted the material facts of this case in Randall I:

On April 6, 2021, an Athens-Clarke County police officer initiated a traffic stop after observing Randall’s vehicle failing to maintain its lane while traveling on College Station Road. During the traffic stop, the officer smelled the odor of alcohol when Randall spoke to him and observed that Randall had glassy eyes and difficulty with balance when he exited the vehicle. The officer arrested Randall for DUI, read Randall the statutory implied consent notice for drivers aged 21 years and over, and requested that Randall submit to a blood test. Randall refused to submit to a blood test, and no test was performed.

(Citation omitted.) 315 Ga. at 198.

Randall moved to suppress evidence of his refusal to consent to

the blood test, arguing that the admission of evidence of his

2 exercising his constitutional right to refuse a blood test violated his

due process rights under the federal and state Constitutions.

Randall further argued that, to the extent OCGA §§ 40-5-67.1 (b)

and 40-6-392 (d), the implied consent statutes, allow the

introduction of such evidence, they also violate due process. The trial

court agreed and ordered suppressed evidence of Randall’s refusal

to consent to a blood test. But the trial court did not confine its

analysis to the arguments actually raised by Randall and went on to

conclude that the implied consent statutes have a chilling effect on

a defendant’s exercise of his constitutional right to refuse a

warrantless search, impermissibly and unduly burden a defendant’s

exercise of his right to refuse warrantless blood testing, and violate

a defendant’s due process rights under the United States and

Georgia Constitutions. See 315 Ga. at 199.

The State appealed, and in Randall I, this Court vacated the

trial court’s order. Because the parties had agreed that evidence of

Randall’s refusal to take the blood test was admissible for the

limited purpose of explaining the absence of blood test results, we

3 held that “the constitutional ruling by the trial court on the

admissibility of blood test refusal evidence [was] unnecessary.” 315

Ga. at 200-201 (1). We also held that, because Randall did not

challenge the constitutionality of OCGA § 40-5-67.1 (b) on the basis

that it chilled his right to refuse a warrantless search, the trial court

erred by expanding the scope of its review to the constitutionality of

the statute. Id. at 201-202 (2).

After the case returned to the trial court, Randall filed an

amended motion to suppress, again arguing that admission of

evidence that he exercised his constitutional right to refuse the

state-administered blood test violates due process, that the implied

consent statutes also violate due process to the extent they permit

the introduction of such evidence, and that the implied consent

statutes impermissibly burdened and chilled his constitutional

rights. Randall also argued that evidence of his refusal was more

prejudicial than probative. While his argument did not expressly

invoke OCGA § 24-4-403, it did necessarily implicate those statutory

principles. See Rule 403 (“Relevant evidence may be excluded if its

4 probative value is substantially outweighed by the danger of unfair

prejudice . . . .”). Following a hearing, the trial court granted

Randall’s amended motion. As an initial matter, in ruling on

Randall’s amended motion, the trial court found that the parties did

not agree that evidence of Randall’s refusal of the blood test was

admissible to explain the absence of a test result as we determined

they had with respect to the prior motion to suppress in Randall I.

Then, employing the same reasoning verbatim as in its first

suppression order, see Randall I, 315 Ga. at 199, the trial court held:

To the extent that OCGA § 40-5-67.1 informs a person that refusing to submit to blood testing may be offered as evidence against them at trial, it needlessly and unnecessarily chills a defendant’s exercise of the constitutional right to refuse a warrantless search. To the extent that OCGA § 40-6-392 (d) allows that evidence to be admitted at trial, it impermissibly and unduly burdens a defendant’s exercise of the right to refuse warrantless blood testing. Therefore, to that extent, OCGA § 40-5-67.1 and [OCGA] § 40-6-392 (d) violate a defendant’s due process rights guaranteed by both the United States and Georgia Constitutions.

The trial court expressly noted that, in light of its ruling on the

constitutional issues, it would not address Randall’s argument made

5 pursuant to Rule 403 that evidence of his refusal to consent was

more prejudicial than probative. The State now appeals.

2. Analysis.

As they did in the trial court, the parties focus their arguments

on the thorny and unresolved issues of constitutional law raised in

Randall’s amended motion to suppress and the trial court’s ruling

on that motion.2 But, as we discuss below, it is not necessary for us

to reach those issues.

Generally speaking, this Court will not reach novel

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897 S.E.2d 444, 318 Ga. 79, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-randall-ga-2024.