Steed v. State, 309 Ga. App. 546

Steed was convicted by Cobb County jury of DUI less safe, driving with suspended license, and improper lane change; prior guilty plea to open-container open beverage offense.
Officers stopped Steed for an improper lane change at roughly 2:30 a.m. after he accelerated in front of an ambulance without signaling.
Miller, a drug-recognition expert, detected alcohol odor; Steed admitted three drinks.
Field sobriety tests and an Alcosensor reading led to Steed’s arrest for less safe to drive; Steed refused breath/blood tests.
A search of Steed’s car revealed an open Bacardi bottle on the passenger side floorboard.
Steed sought a new trial challenging evidentiary rulings and suppression determinations; the court affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of certain hearsay and license-status statements was proper	Steed	State	Yes; admissibility within trial court’s discretion and res gestae determination supported
Whether inflammatory cross-examination remarks violated OCGA 17-8-57	Steed	State	No; remarks were responsive and did not improperly comment on guilt
Whether evidence shows Steed drove with a suspended license	Steed	State	Sustained; evidence showed suspension and notice
Whether cross-exam using driving-record copy was plain error	Steed	State	No; plain-error rule not applicable
Whether trial court’s OCGA 17-8-57 violations occurred in opening/closing and evidence handling	Steed	State	No reversible error; rulings within discretion

Heard v. State, 257 Ga.App. 505 (2002) (res gestae admissibility and weight)
Jones v. State, 270 Ga. 25 (1998) (hearsay and admissibility standards)
Westmoreland v. State, 192 Ga.App. 173 (1989) (evidentiary rulings; relevance)
State v. Gardner, 296 Ga.App. 792 (2009) (plain error and trial-court expressions— OCGA 17-8-57 context)
Branscomb v. State, 272 Ga.App. 700 (2005) (scope of argument; control by court)