Bell v. State, 311 Ga. App. 289

Bell was convicted in 2005 of raping a 14-year-old in November 2003 at a Youth Detention Center in Pelham.
On appeal, Bell challenged the admission of evidence of a prior 1996 acquitted transaction allegedly showing a similar modus operandi.
Bell also challenged the denial of his motion for mistrial after prejudicial statements during voir dire.
The State sought to use the 1996 acquittal to show course of conduct, identity, or intent; Bell claimed collateral estoppel barred this.
The trial court allowed the 1996 acquittal evidence after a Williams v. State pre-trial analysis; Bell was ultimately convicted.
The Georgia Court of Appeals reversed, concluding the voir dire remarks tainted the jury pool and the mistrial should have been granted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior acquitted transaction	Bell	Bell	Reversed; collateral estoppel barred use of the prior acquittal evidence
Effect of prejudicial voir dire remarks on mistrial	Bell	Bell	Reversed; mistrial required due to tainted jury pool

Williams v. State, 261 Ga. 640 (Ga. 1991) (pre-trial admissibility framework for prior acts)
Banks v. State, 185 Ga. App. 851 (Ga. App. 1988) (collateral estoppel in prior acquittals)
Moore v. State, 254 Ga. 674 (Ga. 1985) (focus on disputed issues resolved in prior trial)
Salcedo v. State, 258 Ga. 870 (Ga. 1989) (collateral estoppel—whether issues were resolved in defendant's favor)
Cartwright v. State, 242 Ga. App. 825 (Ga. App. 2000) (prior acts admissible when identity not at issue)
Riley v. State, 181 Ga. App. 667 (Ga. App. 1987) (collateral estoppel limits relitigation of intent)
Lingerfelt v. State, 147 Ga. App. 371 (Ga. App. 1978) (prejudice from improper statements requires careful handling)
White v. State, 268 Ga. 28 (Ga. 1997) (standard for mistrial when prejudicial conduct occurs)
Smith v. Phillips, 455 U.S. 209 (Supreme Court 1982) (due process and prejudicial impact on juror impartiality)