State v. Randall, 318 Ga. 79

Antonio Randall was stopped and arrested for DUI after an officer observed signs of impairment and Randall refused to submit to a blood test.
At trial, Randall moved to suppress evidence of his refusal, arguing its admission violated due process under federal and state constitutions.
The trial court initially suppressed the evidence on constitutional grounds, but the Georgia Supreme Court vacated that order (Randall I), finding constitutional resolution unnecessary.
On remand, the trial court again suppressed the evidence, relying on constitutional reasoning, and declined to address Randall's argument that its probative value was substantially outweighed by unfair prejudice under OCGA § 24-4-403 (Rule 403).
The State appealed the suppression; the Georgia Supreme Court reviewed whether the trial court erred by not considering the Rule 403 issue first.

Issue	Randall’s Argument	State’s Argument	Held
Suppression on Due Process	Admission of refusal evidence violates due process rights.	Statutes allow admission of refusal evidence; constitutional ruling is unnecessary if evidence is admissible anyway.	Vacated and remanded; trial court must address evidentiary (Rule 403) issue before constitutional question.
Statutory Balancing (Rule 403)	Evidence of refusal is more prejudicial than probative and should be excluded under Rule 403.	(Not expressly addressed in record; likely position is that probative value outweighs prejudice.)	Trial court must consider and resolve this issue before constitutional analysis.
Relevance of Refusal Evidence	Refusal evidence may not be relevant; if not relevant, it shouldn’t be admitted.	(Not expressly addressed in record.)	Trial court must determine relevance first, as part of evidentiary analysis.
Scope of Statutory Review	Statutes (OCGA §§ 40-5-67.1, 40-6-392) impermissibly burden constitutional rights.	No need for constitutional inquiry if threshold evidentiary issues resolve the matter.	Constitutional analysis is unnecessary if statutory issues resolve the exclusion question.

State v. Randall, 315 Ga. 198 (Ga. 2022) (prior Georgia Supreme Court ruling in same case vacating trial court’s constitutional ruling as unnecessary)
State v. Mondor, 306 Ga. 338 (Ga. 2019) (requirement to resolve statutory issues before reaching constitutional claims)
In re C.C., 314 Ga. 446 (Ga. 2022) (principle of constitutional avoidance—courts should not decide constitutional issues unnecessarily)
Olds v. State, 299 Ga. 65 (Ga. 2016) (trial courts have principal discretion over applying Rule 403 evidence balancing)