Wilson v. Wilson

596 S.E.2d 392, 277 Ga. 801
CourtSupreme Court of Georgia
DecidedApril 27, 2004
DocketS04F0234
StatusPublished
Cited by18 cases

This text of 596 S.E.2d 392 (Wilson v. Wilson) 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
Wilson v. Wilson, 596 S.E.2d 392, 277 Ga. 801 (Ga. 2004).

Opinions

Carley, Justice.

E.D. Wilson, Jr. (Husband) brought this divorce action against Brenda Copeland Wilson (Wife). After a bench trial, the trial court entered a final judgment and divorce decree, resolving several issues including equitable division of property and alimony. We granted a discretionary appeal from this final divorce decree pursuant to this Court’s pilot project. See Wright v. Wright, 277 Ga. 133 (587 SE2d 600) (2003).

1. When Wife’s counsel requested leave to make her closing argument, the trial court refused, stating, “Wall have about worn me out. I don’t think I want to hear any closing arguments.” Wife contends that this denial of the right to closing argument is reversible error.

“Courts around the country are split as to whether there is an absolute right to closing argument in civil cases. . . . [T]here are at least three general approaches.” In re Emileigh F., 724 A2d 639, 643 [802]*802(III) (Md. 1999). See also Anno., 38 ALR2d 1396, §§ 4, 5. In some jurisdictions, the right is constitutional and absolute, while in others, the matter is entirely discretionary in civil, non-jury trials. In re Emileigh F, supra. Still other courts take an intermediate approach, holding that, as a matter of non-constitutional common law, the right to closing argument exists even in civil, non-jury trials, but may be precluded when no factual issues exist or when the parties waive the opportunity. In re Emileigh F., supra. Georgia takes this intermediate position, at least where, as here, the issue is raised with respect to the main trial, and not merely an interlocutory proceeding. Madison v. Montgomery, 206 Ga. 199 (3) (56 SE2d 292) (1949) (bench trial); Early & Lane v. Oliver & Norton, 63 Ga. 11,18 (2) (1879). Compare Jolly v. Catoosa County Bd. of Ed., 171 Ga. 193 (2) (154 SE 788) (1930). Under the intermediate approach, the right to closing argument may be limited with respect to time, as in OCGA § 9-10-180, and content so as to preclude improper argument, but trial courts may not totally deny the right. Fuhrman v. Fuhrman, 254 NW2d 97, 101 (IV) (N.D. 1977).

Ample opportunity for full argument is certainly an important right to the parties, and if denied on the main trial of a case, civil or criminal, the denial would furnish sufficient reason, generally, for a new trial. [Cits.] . . . Courts are as much bound to abstain from violating rights of practice as rights of principle. The method ordained by law to reach justice is through a trial; and no final trial is full and complete under our system, without the argument of the parties ... , if they choose to exercise the privilege of discussion. So useful is the aid of argument in elucidating the real merits of a controversy and distinguishing the right side from the wrong, that for the sake of its business utility, aside from its bearing on the mental satisfaction of the parties, there is every reason for vindicating the privilege, as a mere privilege, in all final trials.

Early & Lane v. Oliver & Norton, supra at 18-19 (2) (Bleckley, J.).

Argument, as the United States Supreme Court said in Herring v. New York, [422 U. S. 853 (95 SC 2550, 45 LE2d 593) (1975)], may in some cases leave a judge just where it found him. “But just as surely, there will be cases where closing argument may correct a premature misjudgment and avoid an otherwise erroneous verdict. And there is no certain way for a trial judge to identify accurately which cases these will be, until the judge has heard the closing summation of coun[803]*803sel.” [Cit.] And, as the same court points out in a footnote, closing argument in a bench trial may be even more important than in a jury trial, since a judge reaches his decision without the “stimulation of opposing viewpoints inherent in the collegial decision-making process of a jury.” [Cit.]

Fuhrman v. Fuhrman, supra at 102 (IV).

The dissent completely misreads Early & Lane v. Oliver & Norton, supra. Justice Bleckley wrote eloquently regarding much more than the mental satisfaction of the parties. On pages 18-20 of the opinion, he carefully set forth the following three points: (1) Closing argument is an absolute right which, if the parties choose to exercise it, must be vindicated in all final bench trials. (2) Closing argument may or may not be subject to some discretion in interlocutory proceedings. (3) Because the result of an application for interlocutory injunction, unlike the result of a final trial, is largely a matter of discretion, reversal of the interlocutory order is not warranted if the appellant was not harmed. Jolly v. Catoosa County Bd. of Ed., supra, involves a petition for interlocutory injunction and, thus, is distinguishable from this case.

The dissent also misunderstands Madison v. Montgomery, supra at 205 (3), involving a bench trial in a child custody case, where this Court, citing another opinion authored by Justice Bleckley, VanDyke v. Martin, 55 Ga. 466 (1875), reaffirmed his understanding of the right to closing argument. “The right to present argument is a valuable and substantial one, which all litigants have in the trial of cases, and one which should never be denied; but it is a right which may be waived expressly or by conduct.” Madison v. Montgomery, supra at 199 (3). This Court affirmed the judgment in that case only because counsel waived argument by his conduct when the trial judge offered “to correct an error, if one had in fact been committed . . . .” Madison v. Montgomery, supra at 206 (3). Although the trial court in Madison may have been unsure of the absolute right to closing argument, this Court did not express any such uncertainty, and its reliance on waiver was essential to affirmance. In the instant case, Wife’s “failure to object does not constitute a waiver since counsel’s request of the trial court for [closing argument] was refused. [Cits.]” Hendricks v. State, 277 Ga. 61, 63 (3), fn. 3 (586 SE2d 317) (2003). Thus, Wife clearly did not waive her right to closing argument. Compare Madison v. Montgomery, supra at 205-206 (3).

Furthermore, this case is not one in which closing argument was unnecessary due to an absence of any conflict in the evidence. See Ruskell, Davis and Shulman’s Ga. Prac. and Proc. (2001 ed.), § 19-20. Compare Hooks v. Frick & Co., 75 Ga. 715 (5) (1885). The trial court was presented with difficult, disputed issues of fact regarding ali[804]*804mony and property division. See Fuhrman v. Fuhrman, supra at 102 (IV) (divorce case involving issues of child custody and support and property division); In re Emileigh F, supra at 645 (III).

We conclude our analysis by turning once more to the wisdom of Justice Bleckley:

Argument is not only a right, but a material one. It is not a mere ornamental fringe, hung upon the border of a trial. Trial, under our system, is a co-operation of minds - a grave and serious consultation over what should be done and how the end should be accomplished.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Eugene Smith v. Ray Laney
Court of Appeals of Georgia, 2021
Graybill v. Attaway Construction & Associates, LLC
802 S.E.2d 91 (Court of Appeals of Georgia, 2017)
Gordon v. Abrahams
769 S.E.2d 544 (Court of Appeals of Georgia, 2015)
State v. Jackson
764 S.E.2d 395 (Supreme Court of Georgia, 2014)
Gilmer County Board of Tax Assessors v. Spence
711 S.E.2d 51 (Court of Appeals of Georgia, 2011)
Alexandrov v. Alexandrov
709 S.E.2d 778 (Supreme Court of Georgia, 2011)
Miller v. Miller
705 S.E.2d 839 (Supreme Court of Georgia, 2010)
Killingsworth v. Killingsworth
686 S.E.2d 640 (Supreme Court of Georgia, 2009)
HANSON STAPLE CO., INC. v. Eckelberry
677 S.E.2d 321 (Court of Appeals of Georgia, 2009)
GIW Industries, Inc. v. JerPeg Contracting, Inc.
530 F. Supp. 2d 1323 (S.D. Georgia, 2008)
Jenkins v. Sallie Mae, Inc.
649 S.E.2d 802 (Court of Appeals of Georgia, 2007)
Chubbuck v. Lake
635 S.E.2d 764 (Supreme Court of Georgia, 2006)
Bull v. Bull
622 S.E.2d 326 (Supreme Court of Georgia, 2005)
Hayes v. Hayes
620 S.E.2d 806 (Supreme Court of Georgia, 2005)
Wilson v. Wilson
612 S.E.2d 797 (Supreme Court of Georgia, 2005)
Stewart v. Cardella
602 S.E.2d 915 (Court of Appeals of Georgia, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
596 S.E.2d 392, 277 Ga. 801, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-wilson-ga-2004.