Adams v. State, 306 Ga. 1

In July 2016 Gregory Adams was arrested after a one-vehicle accident and declined the state blood test; the trooper initiated an administrative license suspension (ALS) under OCGA § 40-5-67.1.
At the ALS hearing the trooper and Adams' counsel executed a written agreement providing the trooper would withdraw the sworn ALS report if Adams pled guilty to the DUI by a specified date; if Adams failed to plead, the trooper could seek reinstatement of the suspension.
Adams did not plead guilty and instead was tried on DUI, failure to maintain lane, and following too closely; the State introduced the ALS agreement (and trooper testimony about it) at trial.
The State also introduced evidence of a 2011 DUI arrest in which Adams declined the blood test and later pled guilty to reckless driving.
Adams did not object at trial to admission of the ALS agreement and later appealed, arguing the agreement should have been excluded and that evidence of the 2011 incident was unduly prejudicial under OCGA § 24-4-403.
The Court of Appeals affirmed; the Georgia Supreme Court granted certiorari and affirmed the Court of Appeals' judgment, holding Adams waived his first claim and failed to carry his burden on the Rule 403 challenge given the incomplete appellate record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of ALS agreement at criminal trial	Adams: Flading was wrongly decided or distinguishable; agreement should be excluded	State: ALS stipulation admissible; no timely objection at trial	Waiver: Adams affirmatively waived objection at trial by stating "we don't object," so no plain error review; admission stands
Admission of 2011 DUI arrest under OCGA § 24-4-403	Adams: Evidence was more prejudicial than probative and should have been excluded	State: Evidence relevant to intent/similarity; probative value outweighs prejudice	No reversible error shown: appellant bore burden to demonstrate imbalance but designated an incomplete record, so appellate review cannot find error

Flading v. State, 327 Ga. App. 346 (Ga. Ct. App.) (trial court did not abuse discretion admitting ALS stipulation at DUI trial)
State v. Kelly, 290 Ga. 29 (Ga. 2011) (four-prong plain-error framework)
Anthony v. State, 302 Ga. 546 (Ga. 2017) (preservation rules for evidentiary objections; plain error review under OCGA § 24-1-103(d))
Jones v. State, 301 Ga. 544 (Ga. 2017) (Rule 403 balancing for extrinsic-act evidence requires assessment of all surrounding circumstances)
King v. State, 300 Ga. 180 (Ga. 2016) (appellant bears burden to prove trial error by the record)