Wallace v. State

915 S.E.2d 625, 321 Ga. 505
CourtSupreme Court of Georgia
DecidedMay 6, 2025
DocketS25A0416
StatusPublished

This text of 915 S.E.2d 625 (Wallace v. State) 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
Wallace v. State, 915 S.E.2d 625, 321 Ga. 505 (Ga. 2025).

Opinion

321 Ga. 505 FINAL COPY

S25A0416. WALLACE v. THE STATE.

WARREN, Presiding Justice.

Antonio Wallace, who was convicted of felony murder in 2011

and has a pending habeas case, seeks original copies of autopsy

photographs that were collected as part of the criminal case against

him. After he requested these photographs under the Open Records

Act and the District Attorney refused to provide them, he filed a

motion seeking disclosure in the superior court where he was

convicted.

OCGA § 45-16-27 (d) excludes autopsy photographs from

required disclosure under the Open Records Act, OCGA § 50-18-70

et seq., with a few exceptions, including if the disclosure is for

“medical purposes” or is “in the public interest.” Wallace argues that

his request for autopsy photographs fits within these two exceptions.

The trial court found those arguments unconvincing and denied his

motion. We affirm the trial court’s order. 1. In January 2011, Wallace was convicted of felony murder in

Ware County. This Court affirmed his conviction in 2020. See

Wallace v. State, 309 Ga. 823, 823 (848 SE2d 72) (2020). Wallace

asserts that in December 2021, he filed a habeas corpus petition in

Wheeler County that is still pending. In August 2024, Wallace filed

in his criminal case a “motion for limited disclosure of original trial

exhibits,” requesting “an order permitting the limited disclosure of

the state’s original autopsy evidence, particularly photos from the

autopsy, to Dr. Jan Gorniak.”

In his motion, Wallace asserted the following facts. At his trial

for felony murder, evidence was presented that the autopsy of the

victim was conducted in Florida by a medical examiner licensed in

Florida. In preparing his habeas petition, Wallace retained the

services of Dr. Jan Gorniak, the former Chief Medical Examiner of

Fulton County. Wallace asked Dr. Gorniak to review the victim’s

autopsy because Wallace believed that his trial counsel may have

been ineffective by failing to argue that the autopsy was improper

because it was not completed by a medical examiner licensed in

2 Georgia.

Dr. Gorniak asked to see the original autopsy photographs

because “the copies provided in discovery and in Wallace’s copy of

the trial exhibits were blurry” and in “black and white.” Wallace’s

counsel filed “a request to review the District Attorney’s file under

the Open Records Act,” and included a request that the District

Attorney’s office send the original autopsy photographs to Dr.

Gorniak. The District Attorney’s office “declined to make the

materials available” to Dr. Gorniak, citing OCGA § 45-16-27 (d),

which, with a few exceptions, exempts autopsy photographs from

required disclosure under the Open Records Act. Wallace argued

that his requested disclosure fits within exceptions in OCGA § 45-

16-27 (d) that allow for disclosure of autopsy photographs if the

requested disclosure is for “medical purposes” or “in the public

interest.”

On September 18, 2024, the trial court held a hearing on

Wallace’s motion. Wallace’s counsel argued that Dr. Gorniak’s

review of the autopsy photographs was necessary to establish

3 prejudice for a claim of ineffective assistance of counsel for failing to

object to the autopsy. The victim’s sister testified that the victim

died in a hospital in Florida and that his family opposed disclosure

of the autopsy photographs. The trial court denied Wallace’s motion.

Wallace now appeals, raising the same arguments he did in the trial

court.

2. Wallace seeks the autopsy photographs under the Open

Records Act, OCGA § 50-18-70 et seq. In relevant part, OCGA § 50-

18-71 (a) says: “All public records shall be open for personal

inspection and copying, except those which by order of a court of this

state or by law are specifically exempted from disclosure.” OCGA §

45-16-27 (d) provides a specific exemption from disclosure for

autopsy photographs: “Autopsy photographs shall not be subject to

disclosure pursuant to [the Open Records Act].”

That exemption from disclosure does not apply, however, “to

the disclosure of such photographs to . . . physicians for medical

purposes.” OCGA § 45-16-27 (d). The statute also provides:

A superior court may, in closed criminal investigations,

4 order the disclosure of such photographs upon findings in writing that disclosure is in the public interest and that it outweighs any privacy interest that may be asserted by the deceased’s next of kin.

Id. Wallace argues that the autopsy photographs he seeks are

subject to disclosure because the disclosure is for “medical purposes”

and “in the public interest” under OCGA § 45-16-27 (d).

A. “Medical Purposes” Exception

Wallace argues that the disclosure of the autopsy photographs

is for “medical purposes” under OCGA § 45-16-27 (d) because Dr.

Gorniak will “review the autopsy photos” and “form an opinion”

about the autopsy that was conducted in Florida. However, at the

hearing on his motion, Wallace acknowledged that the purpose of

this review was to investigate a potential claim of ineffective

assistance of trial counsel that he may raise in his habeas corpus

case. Based on Wallace’s representations, the trial court found that

the “purpose of [Wallace’s requested] disclosure is so that the doctor

may review the autopsy photos, form an opinion, and ultimately

testify in the habeas proceeding, not the furtherance of any medical

5 purpose,” and concluded that the “requested disclosure is

indisputably for a legal purpose.”

We agree with the trial court. Indeed, we cannot say that the

investigation or development of a claim of ineffective assistance of

counsel is a “medical purpose” under OCGA § 45-16-27 (d).

Dictionary definitions of “medical” from around the time OCGA § 45-

16-27 (d) was enacted suggest that a “medical” purpose means

related to the practice of medicine.1 See, e.g., The American Heritage

Dictionary, Fourth Edition (Houghton Mifflin Company 2000) at

1091 (defining “medical” as “1. Of or relating to the study or practice

of medicine. 2. Requiring treatment by medicine”); Merriam-

Webster’s Collegiate Dictionary, Eleventh Edition (Merriam

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915 S.E.2d 625, 321 Ga. 505, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wallace-v-state-ga-2025.