Timothy Ransom v. State

CourtCourt of Appeals of Georgia
DecidedNovember 27, 2012
DocketA12A0806
StatusPublished

This text of Timothy Ransom v. State (Timothy Ransom 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
Timothy Ransom v. State, (Ga. Ct. App. 2012).

Opinion

THIRD DIVISION MILLER, P. J., RAY 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. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

November 27, 2012

In the Court of Appeals of Georgia A12A0806. RANSOM v. THE STATE.

B RANCH, Judge.

Following a jury trial, Timothy Lamar Ransom was convicted of two counts of

aggravated assault 1 and three counts of aggravated battery.2 Ransom now appeals from

the denial of his motion for a new trial, asserting that the trial court erred in failing to

grant a mistrial following the inadvertent admission of evidence of Ransom’s bad

character and in refusing to instruct the jury on the law of self-defense. We find no

error and affirm.

Viewed in the light most favorable to the verdict, Goolsby v. State, 299 Ga.

App. 330-331 (682 SE2d 671) (2009), the record shows that Mario Freeman arranged

1 OCGA § 16-5-21 (a). 2 OCGA § 16-5-24 (a). for appellant to purchase approximately two pounds of marijuana from a third party.

Ransom, together with his brother Michael, Freeman, and another acquaintance,

Robert Hull, went together to the apartment complex where the drug transaction was

scheduled to occur. After arriving in the parking lot of the complex, Ransom gave

$2,400 in cash to Freeman. He then remained in the parking lot while Freeman and

Hull went into the designated apartment, where they were robbed at gunpoint.

Freeman returned to Ransom without the drugs or the money and explained what had

happened, whereupon Ransom became very angry about the loss of his money.

Ransom and his companions then drove to Ransom’s home, where they found

another group of men waiting in the yard. A disagreement arose over who was to

blame for the loss of the money. Ransom then went into his house, returned holding

a gun, and asked Hull “where’s my . . . money?” When Hull responded that he did not

know, several of the men, including Ransom, proceeded to beat Hull until he was

unconscious. They then dragged Hull down the street, and dumped his body on the

side of the road. When Hull was discovered by emergency personnel, his eyes were

swollen shut, his jawbone and orbital bone were broken, he had lost a number of teeth,

and his head injuries were so severe that they significantly impacted his cognitive

2 functioning. At trial, Ransom testified in his own defense and stated that he was not

present at the time of the beating.

1. The record shows that as part of its case in chief, the State sought to admit

a recorded version of Ransom’s statement to an investigator at the Jackson County

Sheriff’s Office. Prior to trial, the parties agreed to redact those portions of the

statement referencing Ransom’s prior criminal history and the State prepared a

proposed redacted version. The State then provided a transcript of the proposed

redacted statement to defense counsel, and defense counsel approved its use. The

agreed-upon transcript, however, was thereafter misplaced and a new one was

prepared by the prosecutor’s office. The replacement transcript mistakenly included

a single reference to Ransom’s time in prison.

At trial, the jurors listened to the audio recording of the statement and were

provided with copies of the replacement transcript. At the time the transcript was

published to the jury, defense counsel had not been informed that the transcript

represented a replacement of the one he had reviewed and approved and he was

therefore unaware of any changes to the document. Although the State provided

defense counsel with a copy of the transcript at the time it was presented to the jury,

defense counsel did not review it, because he believed that he had already seen and

3 approved the document. Defense counsel did not notice the error until the jury

deliberations had begun, at which time he moved for a mistrial. Finding that the

failure to properly redact the transcript was an accident, the trial court denied the

motion for a mistrial, but did provide a curative instruction to the jury, directing them

to disregard any evidence that might indicate that “this [d]efendant may have been in

trouble with the law before.” The trial court then polled each juror individually to

determine if he or she would be able to disregard any such inappropriate information.

On appeal, Ransom asserts that the trial court erred in failing to grant a mistrial

We disagree. “We review a trial court’s denial of a motion for a mistrial based on the

injection of improper character evidence for manifest abuse of the court’s

discretion.”(Citation and punctuation omitted.) Adams v. State, 276 Ga. App. 319, 321

(2) (623 SE2d 525) (2005).” [T]he . . . court’s discretion . . . will not be disturbed so

long as proper remedial measures are taken to ensure the right to a fair trial.”

(Footnote omitted.) Culler v. State, 277 Ga. 717, 719 (3) (594 SE2d 631) (2004). In

light of the inadvertent nature of the introduction of the improper evidence, as well as

the remedial steps taken by the trial court, we find no abuse of discretion in this case.

See Hunter v. State, 281 Ga. 526, 530 (3) (640 SE2d 271) (2007).

4 In Hunter, our Supreme Court found that curative instructions were an adequate

remedy where the defendant’s character was improperly placed into evidence because

of the State’s failure to properly redact references to the defendant’s prior jail sentence

from a recording of the defendant’s interview with police. Id. Accord Culler, supra.

(trial court did not abuse discretion in denying defendant’s motion for mistrial based

upon State’s witness improperly referencing defendant’s prior jail sentence when trial

court found that the witnesses’ improper statement was inadvertent and gave a

curative instruction to jurors). Here, although the trial court did not provide a curative

instruction immediately after the introduction of the improper evidence, it did so as

soon as defense counsel raised its objection to the improperly redacted transcript, and

it also polled the jurors as to their ability to disregard that evidence. Under the relevant

law, therefore, we must conclude that the trial court did not abuse its discretion in

denying the motion for a mistrial. See Kerdpoka v. State, 314 Ga. App. 400, 402-403

(2) (724 SE2d 419) (2012) (no abuse of discretion by trial court in denying motion for

a mistrial, finding that improper reference to defendant’s DUI was inadvertent and that

trial court provided a prompt curative instruction).

5 2. Ransom contends that the trial court erred in refusing trial counsel’s request

for jury instructions on self-defense.3 “To authorize a jury instruction on a subject,

there need only be produced at trial slight evidence supporting the theory of the

charge. Whether the evidence presented is sufficient to authorize the giving of a

charge is a question of law.” (Citations and punctuation omitted.) McNeal v. State, 289

Ga. 711, 714 (4) (715 SE2d 95) (2011).

Because self-defense represents an affirmative defense, we agree with the trial

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Related

Hunter v. State
640 S.E.2d 271 (Supreme Court of Georgia, 2007)
Adams v. State
623 S.E.2d 525 (Court of Appeals of Georgia, 2005)
Goolsby v. State
682 S.E.2d 671 (Court of Appeals of Georgia, 2009)
Lightning v. State
676 S.E.2d 780 (Court of Appeals of Georgia, 2009)
Culler v. State
594 S.E.2d 631 (Supreme Court of Georgia, 2004)
Williams v. State
688 S.E.2d 650 (Court of Appeals of Georgia, 2009)
Hicks v. State
695 S.E.2d 195 (Supreme Court of Georgia, 2010)
McNeal v. State
715 S.E.2d 95 (Supreme Court of Georgia, 2011)
KERDPOKA v. State
724 S.E.2d 419 (Court of Appeals of Georgia, 2012)

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