State v. Sara Walker

CourtCourt of Appeals of Georgia
DecidedJuly 13, 2020
DocketA20A0544
StatusPublished

This text of State v. Sara Walker (State v. Sara Walker) 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. Sara Walker, (Ga. Ct. App. 2020).

Opinion

WHOLE COURT

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

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

July 2, 2020

In the Court of Appeals of Georgia A20A0544. THE STATE v. WALKER.

HODGES, Judge.

After the State’s witness failed to appear at a bench trial, the trial court

dismissed this misdemeanor prosecution of Sara Walker. The dismissal order did not

specify whether the dismissal was with or without prejudice. The State filed the

instant appeal, arguing that the dismissal order amounted to an impermissible

dismissal with prejudice because the statute of limitation had expired, thus barring the

State from filing another accusation. Because the trial court’s dismissal functioned

as an impermissible dismissal with prejudice, we vacate the judgment below and

remand the case.

Walker was arrested on December 30, 2016, and ultimately charged with

driving under the influence of alcohol – per se (OCGA § 40-6-391 (a) (5)), driving under the influence of alcohol – less safe (OCGA § 40-6-391 (a) (1)), reckless driving

(OCGA § 40-6-390), and following too closely (OCGA § 40-6-49). The case was

called for a bench trial on May 28, 2019, outside the two-year statute of limitation for

misdemeanor offenses. See OCGA § 17-3-1 (e) (“Prosecution for misdemeanors shall

be commenced within two years after the commission of the crime.”).

At the bench trial, when Walker announced ready, the State declared that it was

not ready because the arresting officer, who had been properly subpoenaed, was

unavailable. Although the trial court found that the State “was given a long time to

attempt to reconnect with the officer on this issue[,]” the officer could not be reached.

Walker moved to dismiss the charges for want of prosecution, and on May 31, 2019,

the trial court granted that motion nunc pro tunc to May 28, 2019, without stating

whether the dismissal was with or without prejudice. The State then filed the instant

appeal.1

On appeal, the State contends that because the two-year statute of limitation for

prosecuting misdemeanors had expired and as a result, it could not re-accuse Walker,

1 Although the State indicated that it would file a transcript of the proceedings with this appeal, it did not do so. This lack of a transcript is not fatal to the State’s appeal, as the error is apparent from the face of the trial court’s order. See generally Cameron v. Miles, 311 Ga. App. 753, 755 (1) (716 SE2d 831) (2011) (finding transcript not essential where trial court’s error appears on the face of its order).

2 the unspecified dismissal necessarily functioned as an impermissible dismissal with

prejudice.2

Our law is abundantly clear that criminal charges may not be dismissed with

prejudice. See State v. Luttrell, 207 Ga. App. 116 (427 SE2d 95) (1993) (trial court

lacks authority to enter dismissal with prejudice for want of prosecution in criminal

case); State v. Cooperman, 147 Ga. App. 556, 558 (2) (249 SE2d 358) (1978) (“The

Civil Practice Act ([OCGA § 9-11-41 (b)]) provides for dismissal with prejudice of

[c]ivil cases, but the court knows of no statutory or case authority which permits

dismissals in [c]riminal cases.”). In our recent opinion, State v. Banks, 348 Ga. App.

876, 879 (825 SE2d 399) (2019), as in this case, the trial court dismissed charges

against a number of defendants for want of prosecution in an order that did not

specify whether the dismissals were with or without prejudice. As to the dismissals

entered in cases where the statute of limitation had indisputably run, thus barring the

2 We note that if the statute of limitation is approaching and the State needs more time to prepare its case, it has the sole right to seek an entry of nolle prosequi, which, if granted, extends its limitation period by six months. See State v. LeJeune, 276 Ga. 179, 184 (4) (576 SE2d 888) (2003) (“Only the State may initiate a nolle prosequi order.”); accord OCGA § 17-8-3; see also OCGA § 17-3-3 (“If an indictment is found within the time provided for in Code Section 17-3-1 or 17-3-2, or other applicable statute, and is quashed or a nolle prosequi entered, the limitation shall be extended six months from the time the first indictment is quashed or the nolle prosequi entered.”).

3 State from re-accusing, this Court found that those dismissals functioned as

dismissals with prejudice. Id. at 880, citing State v. Grimes, 194 Ga. App. 736, 736-

737 (392 SE2d 727) (1990) (affirming dismissal of accusation where “the State may

file another accusation against appellee prior to the expiration of the period of

limitation and prosecute him on that accusation”). In the instant appeal, the State is

barred from re-accusing Walker because the statute of limitation has run and the State

has not sought by nolle prosequi or other means to extend that limitation period.

Thus, the trial court’s unspecified dismissal necessarily functions as a dismissal with

prejudice, given that there is no longer any possibility for the State to re-accuse

Walker. See State v. Roca, 203 Ga. App. 267, 268 (416 SE2d 836) (1992)

(unspecified dismissal for want of prosecution in criminal case did not amount to a

dismissal with prejudice or acquittal where “State could reaccuse the defendant within

the applicable period of limitations”).

Trial courts are vested with considerable, though not unlimited, authority and

discretion in the conduct of their proceedings. State v. Fiorenzo, 325 Ga. App. 666,

667 (1) (754 SE2d 634) (2014); Ezebuiro v. State, 308 Ga. App. 282, 284 (1) (707

SE2d 182) (2011). As is outlined above, a trial court has the authority to dismiss

criminal accusations without prejudice, but it lacks the authority to dismiss them with

4 prejudice. Because the trial court’s unspecified dismissal necessarily functioned as

a dismissal with prejudice given that the statute of limitation barred the State from re-

accusing, the trial court’s authority is neither implicated nor impinged by our

decision, as the trial court had no authority to do what our law prohibits it from doing.

Judgment vacated and case remanded. Reese, P. J., and Mercier, J., concur.

Dillard, P. J., Gobeil, Coomer, Pipkin, and Colvin, JJ., concur fully and specially.

McFadden, C. J., Barnes, P. J., and Doyle, P. J., dissent. Miller, P. J., Rickman,

Brown, and Markle, JJ., concur in the judgment only of the dissent. A20A0544. THE STATE v. WALKER.

GOBEIL, Judge.

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Related

State v. Lejeune
576 S.E.2d 888 (Supreme Court of Georgia, 2003)
Alexander v. State
384 S.E.2d 436 (Court of Appeals of Georgia, 1989)
State v. Colquitt
249 S.E.2d 880 (Court of Appeals of Georgia, 1978)
State v. Cooperman
249 S.E.2d 358 (Court of Appeals of Georgia, 1978)
State v. Fly
387 S.E.2d 347 (Court of Appeals of Georgia, 1989)
State v. Luttrell
427 S.E.2d 95 (Court of Appeals of Georgia, 1993)
State v. Aldridge
577 S.E.2d 863 (Court of Appeals of Georgia, 2003)
State v. Roca
416 S.E.2d 836 (Court of Appeals of Georgia, 1992)
State v. Grimes
392 S.E.2d 727 (Court of Appeals of Georgia, 1990)
State v. Perry
583 S.E.2d 909 (Court of Appeals of Georgia, 2003)
Ambles v. State
383 S.E.2d 555 (Supreme Court of Georgia, 1989)
State v. Webb
386 S.E.2d 891 (Court of Appeals of Georgia, 1989)
EZEBUIRO v. State
707 S.E.2d 182 (Court of Appeals of Georgia, 2011)
Cameron v. Miles
716 S.E.2d 831 (Court of Appeals of Georgia, 2011)
Hatton v. Metropolitan Atlanta Rapid Transit Authority
712 S.E.2d 141 (Court of Appeals of Georgia, 2011)
State v. Outen
764 S.E.2d 848 (Supreme Court of Georgia, 2014)
Loomis v. State
51 S.E.2d 13 (Court of Appeals of Georgia, 1948)
Southall v. State
796 S.E.2d 261 (Supreme Court of Georgia, 2017)
Brooks v. State
804 S.E.2d 1 (Supreme Court of Georgia, 2017)
Price v. State
825 S.E.2d 178 (Supreme Court of Georgia, 2019)

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State v. Sara Walker, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sara-walker-gactapp-2020.