State v. Woods
311 Ga. App. 577
Ga. Ct. App.2011Background
- Six officers went to motel to arrest Lee on aggravated assault; Room 214, where Lee was believed to stay, was unoccupied and not registered to Woods or Lee but manager suspected Lee was in 214.
- Woods opened Room 214 and allowed entry; Lee was later found in Room 306 and arrested; Woods remained in 214 while others searched.
- Woods consented to a room search after being questioned about ownership and staying in the room; he said the safe’s contents were not his and consented to its search.
- Officers opened the room safe with a device; Lee had admitted marijuana and crack in the safe; crack cocaine and paraphernalia were found; Woods was arrested.
- Trial court held Lee had standing as a motel resident and Woods as a frequent overnight guest; it held Woods’s consent invalid due to an illegal detention; the suppression motion was granted.
- On appeal, the court reviews disputed facts for clear error and unresolved factual findings de novo; it accepts the trial court’s ruling on disputed facts but reviews legal conclusions de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to challenge search of Room 214 and safe | State argued Woods had no standing | Woods had a reasonable expectation of privacy as an overnight guest | Lee had standing; Woods had standing as overnight guest |
| Validity of Woods’s consent given detention | State argued consent was voluntary irrespective of detention | Consent was invalid because detention did not de-escalate | Consent invalid; detention illegal; searches suppressed for Woods (and Lee) |
| Inevitable discovery preservation | State relied on inevitable discovery to admit evidence | N/A | Not preserved for review; cannot be considered on appeal |
| De-escalation of police-citizen encounter | State claimed encounter de-escalated after Lee’s arrest | Encounter remained coercive; no free-to-terminate status for Woods | Encounter did not de-escalate; illegal detention persisted |
Key Cases Cited
- Conley v. State, 257 Ga.App. 563, 571 S.E.2d 554 (2002) (Ga. App. 2002) (hearsay admissibility if declarant available for cross-examination)
- Willingham v. State, 296 Ga.App. 89, 673 S.E.2d 606 (2009) (Ga. App. 2009) (evidence of residency and standing considerations)
- Brown v. State, 288 Ga. 404, 703 S.E.2d 624 (2010) (Ga. 2010) (consent to search includes premises on which consent is given)
- Cunningham v. State, 284 Ga.App. 739, 644 S.E.2d 878 (2007) (Ga. App. 2007) (inevitable discovery doctrine discussed in context of exigent circumstances)