Taylor Whitfield Hammill v. State

CourtCourt of Appeals of Georgia
DecidedMay 30, 2014
DocketA14A0450
StatusPublished

This text of Taylor Whitfield Hammill v. State (Taylor Whitfield Hammill 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
Taylor Whitfield Hammill v. State, (Ga. Ct. App. 2014).

Opinion

THIRD DIVISION BARNES, P. J., BOGGS and BRANCH, 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/

May 30, 2014

In the Court of Appeals of Georgia A14A0450. HAMMILL v. THE STATE.

BARNES, Presiding Judge.

This case arises out of the collision of two jet skis on Lake Lanier. The

collision occurred when the defendant, Taylor Whitfield Hammill, struck the other

jet skier from behind at a speed of 30 to 40 mph. Based on evidence that Hammill had

been consuming alcohol and operating his jet ski in a reckless manner, a jury found

him guilty of two counts of serious injury by vessel, one count of reckless operation

of a vessel, and one count of operating a vessel under the influence of alcohol. The

trial court subsequently denied Hammill’s motion for new trial, and this appeal

followed. Hammill maintains on appeal (1) that the State failed to prove proximate

cause, an essential element of the offense of serious injury by vessel; (2) that the trial

court erred in limiting his counsel’s recross-examination of an officer about whether Hammill had refused a State-administered blood test; (3) that the prosecutor

improperly commented in the presence of the jury on his right not to testify and

incriminate himself; (4) that the trial court erred in denying his motion for mistrial or

in failing to give a curative instruction when the prosecutor allegedly made an

improper remark in closing argument regarding Hammill’s refusal to submit to a

State-administered breath or blood test; and (5) that the trial court erroneously

charged the jury on the inference that could be drawn from his refusal to submit to a

State-administered breath or blood test. For the reasons discussed below, we affirm. 1

“Following a criminal conviction, the defendant is no longer presumed

innocent, and we view the evidence in the light most favorable to sustain the verdict.”

Anthony v. State, 317 Ga. App. 807 (732 SE2d 845) (2012). So viewed, the evidence

showed that Hammill, the victim, and the victim’s boyfriend were college friends. On

Saturday, July 25, 2009, they decided to go to Lake Lanier, where the parents of the

victim’s boyfriend owned a lake house.

1 Because the present case was tried before January 1, 2013, the new Georgia Evidence Code does not apply to any of the evidentiary issues addressed in this opinion. See Ga. Laws 2011, Act 52, § 101 (“This Act shall become effective on January 1, 2013, and shall apply to any motion made or hearing or trial commenced on or after such date.”).

2 They arrived at the lake house around 1:00 p.m. and went down to the dock by

the lake, where they stayed for several hours. According to the victim, her boyfriend

and Hammill brought two 24-packs of beer and a bottle of vodka with them to the

lake house. While on the dock, everyone began drinking the beer, and the victim

testified that her boyfriend and Hammill were drinking “a lot, pretty fast.” The

victim’s boyfriend also got out the bottle of vodka and poured it into slices of

watermelon, and everyone began to eat the watermelon “infused with vodka.”

The parents of the victim’s boyfriend who owned the lake house came down

to the dock and also were drinking alcohol. The boyfriend’s father owned two jet skis.

When Hammill and the victim’s boyfriend asked if they could take the jet skis out on

the lake, the mother responded, “Absolutely not, they’re not insured, and you’ve been

drinking.” But when the mother left the dock to go back to the lake house, the father

gave them permission to ride the jet skis as long as they brought them “right back.”

The victim, her boyfriend, and Hammill rode the jet skis out to a small island

on the lake with a beach area, where they played horseshoes and continued to drink

beer. After about 20 minutes, they decided to return to the lake house. The victim was

driving one of the jet skis with her boyfriend as her passenger, while Hammill drove

the other jet ski. According to the victim, even though the water was choppy,

3 Hammill was driving the other jet ski “ridiculously fast,” was sticking out his tongue,

making faces and “doing little silly signs” with his hands, and was swerving back and

forth across the water near the victim and her boyfriend. At one point, Hammill came

within “arm’s length” of the victim and her boyfriend’s jet ski, and the victim told her

boyfriend, “[H]e’s too close. Tell him to back off. It’s freaking me out.” The victim’s

boyfriend then waived his hand back at Hammill in an effort to get him to slow down.

As they continued back to the lake house on the jet skis, the victim’s jet ski hit

a wave, and her boyfriend fell off. The victim stopped her jet ski so that her boyfriend

could swim over and get back on. While the victim’s jet ski was stopped in the water,

Hammill collided with it and struck the victim in the head, causing her to fall into the

water unconscious. The collision occurred in a portion of the lake in Forsyth County.

The victim’s boyfriend and Hammill flagged down a pontoon boat, and

together with the boat owner they were able to get the victim into the boat and back

over to the shore. A bystander on the shore called 911, and Forsyth County

emergency response personnel were dispatched to the scene and transported the

victim to the hospital, where she underwent two brain surgeries and remained

unconscious for approximately two months as a result of the brain trauma she had

suffered. The victim subsequently went through months of speech, occupational,

4 physical, and cognitive therapy. Ultimately, the victim returned to college, and she

was able to recall the events that had transpired at the lake because she did not suffer

any long-term memory problems.

While the victim was transported to the hospital, an officer assigned to the law

enforcement section of the Georgia Department of Natural Resources (“DNR”) who

had been dispatched to the scene began his investigation of the collision and spoke

with Hammill on a nearby dock. The DNR officer took photographs of the jet skis and

video-recorded his investigation and interaction with Hammill using a “pin cam” that

he wore. As a result of his investigation, including his examination of the damaged

jet skis, the officer determined that Hammill had been traveling between 30 to 40 mph

when he struck the rear side of the victim’s jet ski. The officer further determined that

Hammill collided with the victim’s jet ski with such force that his jet ski traveled over

the top of it and struck the victim directly in the head.

As part of his investigation, the officer also found an empty beer can on the jet

ski driven by Hammill. Moreover, while speaking with Hammill, the officer noticed

that he smelled strongly of alcohol, that his eyes were red and glassy, that his speech

was slurred, and that he was unsteady on his feet. After obtaining Hammill’s consent,

5 the officer performed several field sobriety tests for boaters approved by the United

States Coast Guard for use in water-related environments: the horizontal gaze

nystagmus (“HGN”) test, the recitation of the alphabet and counting tests, and the

hand-pat and finger dexterity tests.2 Hammill exhibited six out of six clues of

impairment on the HGN test, had trouble reciting the alphabet and counting

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