State v. Wheeler

849 S.E.2d 401, 310 Ga. 72
CourtSupreme Court of Georgia
DecidedOctober 5, 2020
DocketS20A0758
StatusPublished
Cited by45 cases

This text of 849 S.E.2d 401 (State v. Wheeler) 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. Wheeler, 849 S.E.2d 401, 310 Ga. 72 (Ga. 2020).

Opinion

310 Ga. 72 FINAL COPY

S20A0758. THE STATE v. WHEELER.

WARREN, Justice.

In the early morning hours of March 15, 2017, a fire broke out

in a unit of the Venetian Hills apartment complex, resulting in the

death of tenant George Hughes. Police investigated the fire,

identified Kamara Wheeler as an arson suspect, and on March 18,

2017, arrested her on an unrelated warrant. When officers

interviewed Wheeler about the apartment fire, she admitted that

she started it.1 She was then indicted by a Fulton County grand jury

for one count of malice murder, one count of felony murder

predicated on arson, and four counts of arson in the first degree.

Wheeler’s trial was scheduled to begin on September 3, 2019.

On January 17, 2019, the State provided Wheeler with a “Notice of

1 Because no trial has been held in this case, the above facts are gleaned

from police and fire department incident reports, witness statements, and the trial court’s order denying the State’s Rule 404 (b) “motion,” which is discussed in more detail below. Intent to Present Evidence of Other Acts,” and an amended notice

on August 13, 2019, indicating that it intended to offer evidence

under OCGA § 24-4-404 (b) (“Rule 404 (b)”)2 of three prior instances

in which Wheeler set or attempted to set a fire as proof of her motive

and intent in this case. The State also filed the notice and amended

notice with the trial court. It is not clear from the record whether

the State also filed a separate motion related to the Rule 404 (b)

evidence it intended to offer,3 but the record shows that the trial

2 OCGA § 24-4-404 (b) provides:

Evidence of other crimes, wrongs, or acts shall not be admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible for other purposes, including, but not limited to, proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident. The prosecution in a criminal proceeding shall provide reasonable notice to the defense in advance of trial, unless pretrial notice is excused by the court upon good cause shown, of the general nature of any such evidence it intends to introduce at trial. Notice shall not be required when the evidence of prior crimes, wrongs, or acts is offered to prove the circumstances immediately surrounding the charged crime, motive, or prior difficulties between the accused and the alleged victim. 3 As explained more in Division 4 below, to comply with the requirements

of OCGA § 5-7-1 (a) (5), the State must appeal from a qualifying trial court order “excluding . . . evidence to be used by the state at trial on any motion filed by the state . . . at least 30 days prior to trial” (emphasis supplied), in addition to satisfying the requirements set out in subsections (a) (5) (A) and (a)

2 court held a hearing on August 26, 2019, at which the parties made

presentations on the Rule 404 (b) issue. After the hearing, the trial

court denied what it called the “State’s 404 (b) motion” on September

3, 2019. The State now appeals from that order under OCGA § 5-7-

1 (a) (5), arguing that the trial court abused its discretion in denying

the motion because it omitted key facts from its analysis and

misapplied the three-part test governing the admissibility of “other

acts” evidence under Rule 404 (b). But we do not reach the merits

of those claims. As explained below, we hold that the timing and

(5) (B). Although a Rule 404 (b) notice filed with a trial court may be construed as such a motion, trial courts are “not required to treat [a Rule 404 (b)] notice as a motion filed under OCGA § 5-7-1 (a) (5).” State v. Battle, 344 Ga. App. 565, 567-568 (812 SE2d 1) (2018). Here, even if the State’s Rule 404 (b) notices were construed as motions made under OCGA § 5-7-1 (a) (5), there is still a question about whether the State’s amended notice was filed timely because it was filed on August 13, less than 30 days before the then-scheduled September 3 trial. And if its Rule 404 (b) notices were not construed as § 5-7-1 (a) (5) motions, then the State’s failure to comply with paragraph (a) (5) would serve as an independent basis for dismissing the State’s appeal. But we need not resolve those questions because — as explained below in Division 5 — we dismiss the State’s appeal for failing to comply with the paragraph (a) (5) (B) certification requirement. However, because the trial court ruled on the State’s Rule 404 (b) evidence and styled its order as an “Order Denying State’s 404 (b) Motion,” we refer to the State’s 404 (b) “motion” in this opinion, notwithstanding the lack of clarity as to whether the State’s Rule 404 (b) notices qualified as motions under OCGA § 5-7-1 (a) (5). 3 certification requirements set forth in OCGA § 5-7-1 (a) (5) are

jurisdictional, and that because the State failed to comply with

OCGA § 5-7-1 (a) (5) (B), we lack jurisdiction to hear the State’s

appeal. We therefore dismiss it.

1. Legal Background.

It is well established that “[t]his Court has a duty to inquire

into its jurisdiction to entertain each appeal and review the alleged

errors of the trial court.” Pounds v. State, 309 Ga. 376, 377 (846

SE2d 48) (2020) (citation and punctuation omitted). The State’s

right to appeal in criminal cases is derived from Georgia’s statutory

law, not from its Constitution. See State v. Martin, 278 Ga. 418,

418-419 (603 SE2d 249) (2004). The State is authorized to appeal in

criminal cases under OCGA § 5-7-1 (a).4

OCGA § 5-7-1 (a) sets forth the various circumstances under

4 Before 1973, Georgia law did not provide for appeals by the State in

criminal cases. See Martin, 278 Ga. at 419. See also Ga. L. 1973, p. 297 (now codified, as amended, at OCGA § 5-7-1 et seq.). And before 2013, when the General Assembly added current paragraph (a) (5) to OCGA § 5-7-1, the State had no right to appeal a pre-trial ruling excluding evidence based on general evidentiary rules. See State v. Rosenbaum, 305 Ga. 442, 448 n.9 (826 SE2d 18) (2019).

4 which the State may file an appeal, including, for example, from an

order dismissing an indictment, § 5-7-1 (a) (1); sustaining a plea in

bar, § 5-7-1 (a) (3); suppressing or excluding illegally seized

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