Steve Richardson v. State

CourtCourt of Appeals of Georgia
DecidedOctober 23, 2012
DocketA12A1157
StatusPublished

This text of Steve Richardson v. State (Steve Richardson v. State) 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
Steve Richardson v. State, (Ga. Ct. App. 2012).

Opinion

SECOND DIVISION BARNES, P. J., ADAMS and MCFADDEN, 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/

October 23, 2012

In the Court of Appeals of Georgia A12A1157. RICHARDSON v. THE STATE.

McFADDEN, Judge.

Steve Richardson appeals from the trial court’s order denying his motion for

discharge and acquittal for an alleged violation of his constitutional right to a speedy

trial.1 This is the second appearance of this case before this Court. See Richardson v.

State, 311 Ga. App. 369 (715 SE2d 774) (2011). In the prior appeal, we vacated the

trial court’s order denying Richardson’s motion because it did not contain findings

of fact and conclusions of law consistent with the analysis set forth in Barker v.

Wingo, 407 U.S. 514 (92 SC 2182, 33 LE2d 101) (1972), and Doggett v. United

States, 505 U.S. 647, 651 (112 SC 2686, 120 LE2d 520) (1992), and we remanded for

1 A defendant is entitled to directly appeal the pretrial denial of a constitutional speedy trial claim. See Johnson v. State, 313 Ga. App. 895, 897, n. 7 (723 SE2d 100) (2012). entry of a proper order. See Richardson, 311 Ga. App. at 370. On remand, the trial

court entered a new order containing findings of fact and conclusions of law, and it

is this order that forms the basis for the current appeal. For the reasons discussed

below, we must vacate the new order and remand this case for the trial court’s

reconsideration.

On January 20, 2007, Richardson was arrested for child molestation and other

related charges stemming from an incident that occurred in December 2006 at his

place of work. Richardson was released on bond on January 23, 2007. On February

6, 2007, the grand jury indicted him on charges of child molestation, false

imprisonment, and sexual battery.

On May 1, 2007, Richardson filed a demand for discovery along with other

consolidated motions. The State served him with some discovery materials on June

27, 2007, including copies of the indictment, the arrest warrants, the initial police

report, supplemental police reports, handwritten witness statements, and a Georgia

Crime Information Center report regarding Richardson. The discovery did not include

photographs of the alleged crime scene location that had been taken by a crime scene

photographer, the surveillance video of Richardson and the victim entering a stairwell

2 where the alleged molestation occurred, or the videotaped forensic interview with the

victim, all of which were referenced in a supplemental police report.

On July 11, 2008, Richardson filed a motion to compel in which he sought a

copy of the crime scene photographs, the surveillance video, and the forensic

interview of the victim, as well as updated contact information for the State’s

witnesses. A few days later, on July 14, 2008, Richardson filed a motion for discharge

and acquittal based on the alleged denial of his constitutional right to a speedy trial.

On March 29, 2010, the State served Richardson with supplemental discovery,

providing him for the first time with copies of the crime scene photographs and the

forensic interview. The State did not produce a copy of the surveillance video.

On August 24, 2010, the trial court entered its original order denying

Richardson’s motion for discharge and acquittal, which, as previously noted, this

Court vacated for failure to contain findings of fact and conclusions of law. See

Richardson, 311 Ga. App. at 370. Following remand, on September 29, 2011, the trial

court entered a new order, again denying Richardson’s motion, that contained

findings of fact and conclusions of law and analyzed the case under the framework

enunciated in Barker and Doggett.

3 In its new order, the trial court calculated the length of the delay as the time

that had elapsed between Richardson’s January 20, 2007 arrest and the court’s August

24, 2010 original order denying his motion for discharge and acquittal. The trial court

went on to find that the pretrial delay was presumptively prejudicial; that the length

of the delay was uncommonly long and weighed heavily against the State; that the

reasons for the delay weighed “benignly” against the State because there was no

evidence that the State deliberately attempted to delay the trial or hamper

Richardson’s defense; that Richardson’s 18-month delay in asserting his speedy trial

right weighed heavily against him; and that Richardson’s failure to show prejudice

resulting from the delay should be weighed heavily against him as well. Based on

these findings, the trial court balanced the factors and concluded that Richardson’s

constitutional right to a speedy trial had not been violated. Richardson filed the

instant appeal challenging the trial court’s new order.

We recently summarized the applicable principles and framework for deciding

constitutional speedy trial claims:

Both the United States and Georgia Constitutions grant defendants in criminal cases a right to a speedy trial. U.S. Const. Amend. VI; Ga. Const. Art. I, Sec. I, Para. XI (a). When considering a motion to dismiss on this ground, the court conducts a two-tier analysis

4 [as set out in Barker, 407 U.S. at 522-523 (II), and Doggett, 505 U.S. at 651]. Under the first tier, the court considers whether the delay is long enough to be presumptively prejudicial, and if so, then it considers under the second tier whether the delay constituted a speedy trial violation. In determining whether the delay violated the defendant’s speedy trial right, the court considers [four Barker-Doggett factors:] (1) whether the delay is uncommonly long; (2) the reasons and responsibilities for the delay; (3) the defendant’s assertion of the right to a speedy trial; and (4) the prejudice to the defendant.

The four factors must be considered together, balancing the conduct of the [government] and the defendant on a case-by-case basis. We review a trial court’s decision to deny a motion seeking dismissal for a speedy trial violation under an abuse of discretion standard. . . .

Further, if the trial court significantly misapplies the law or clearly errs in a material factual finding, the trial court’s exercise of discretion can be affirmed only if the appellate court can conclude that, had the trial court used the correct facts and legal analysis, it would have had no discretion to reach a different judgment.

(Citations and punctuation omitted.) Watkins v. State, __ Ga. App. __, __ (1) (Case

No. A12A0246, decided on Apr. 27, 2012). See also State v. Porter, 288 Ga. 524,

525-526 (2) (a) (705 SE2d 636) (2011); Sechler v. State, __ Ga. App. __, __ (Case

5 No. A12A0676, decided on July 6, 2012). Guided by these principles, we turn to the

procedural history and the trial court’s new order entered in this case.

1. Presumptive prejudice.

“For serious crimes that do not involve unusual complexities, one year

generally marks the point at which expected deliberateness in the prosecution of a

criminal matter turns into presumptively prejudicial delay.” (Citation and punctuation

omitted.) Ward v. State, 311 Ga. App. 425, 428 (1) (715 SE2d 818) (2011). The trial

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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)
Williams v. State
686 S.E.2d 407 (Court of Appeals of Georgia, 2009)
Ruffin v. State
663 S.E.2d 189 (Supreme Court of Georgia, 2008)
Mullinax v. State
545 S.E.2d 891 (Supreme Court of Georgia, 2001)
Hayes v. State
680 S.E.2d 182 (Court of Appeals of Georgia, 2009)
Lambert v. State
692 S.E.2d 15 (Court of Appeals of Georgia, 2010)
Teasley v. State
704 S.E.2d 248 (Court of Appeals 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. Ivory
698 S.E.2d 340 (Court of Appeals of Georgia, 2010)
State v. Lattimore
696 S.E.2d 613 (Supreme Court of Georgia, 2010)
Howard v. State
706 S.E.2d 163 (Court of Appeals of Georgia, 2011)
State v. Brown
726 S.E.2d 500 (Court of Appeals of Georgia, 2012)
Kemp v. State
724 S.E.2d 41 (Court of Appeals of Georgia, 2012)
State v. Shirley
714 S.E.2d 636 (Court of Appeals of Georgia, 2011)
Johnson v. State
723 S.E.2d 100 (Court of Appeals of Georgia, 2012)
Williams v. State
717 S.E.2d 640 (Supreme Court of Georgia, 2011)
Weems v. State
714 S.E.2d 119 (Court of Appeals of Georgia, 2011)
Moore v. State
723 S.E.2d 508 (Court of Appeals of Georgia, 2012)

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Steve Richardson v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steve-richardson-v-state-gactapp-2012.