State v. Edwards
307 Ga. App. 267
Ga. Ct. App.2010Background
- Officers approached Edwards outside his home in response to a 911 hang-up and learned of an outstanding warrant via dispatcher.
- Officers arrested Edwards solely based on the outstanding warrant and conducted a search incident to arrest, yielding marijuana.
- Edwards moved to suppress the marijuana, challenging the existence of the warrant at the time of arrest.
- Trial court granted suppression, finding lack of proof that a warrant existed when Edwards was arrested.
- State relied on Harvey v. State to justify arrest and search despite potential lack of a valid warrant.
- Appellate court reversed, holding dispatch-confirmed warrant provided probable cause to arrest and search was lawful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether dispatcher’s warrant information supplied probable cause | Edwards | State | Arrest supported by probable cause from dispatch |
| Whether the State proved the warrant’s existence at arrest | Edwards | State | State must prove warrant existed; nevertheless dispatch info authorized arrest under Harvey |
| Whether hearsay testimony about the dispatcher is admissible | Edwards | State | Hearsay testimony admissible to establish probable cause under Harvey framework |
Key Cases Cited
- Harvey v. State, 266 Ga. 671 (Ga. 1996) (probable cause based on dispatch information; validity of arrest depends on current knowledge at arrest time)
- Sosebee v. State, 303 Ga.App. 499 (Ga. App. 2010) (hearsay evidence insufficient to prove warrant absence without personal knowledge)
- Baez v. State, 206 Ga.App. 522 (Ga. App. 1992) (state must prove existence of warrant when challenged; exclusionary rule)
- Singleton v. State, 194 Ga.App. 423 (Ga. App. 1990) (citation discussed in Harvey context regarding probable cause from warrants)
- State v. Stringer, 258 Ga. 605 (Ga. 1988) (probable cause standards; computer bulletin not alone sufficient)