The State v. Bragg, 332 Ga. App. 608

Bragg challenged an indictment for violating Georgia’s Employment Security Law as barred by OCGA § 17-3-1 (c)’s four-year statute of limitation.
The State contends tolling under OCGA § 17-3-2 (2) applies for the period the crime was unknown.
Two DOL databases track claimants and wages; a skip-trace program compares them quarterly using Social Security numbers.
A quarterly wage audit inquiry is sent to employers when the system shows a claimant worked while on unemployment benefits.
Bragg received unemployment benefits in 2009; the DOL identified her as early as January 1, 2010; employer confirmed wages on February 2, 2010.
The State waited to charge Bragg until January 7, 2014; Bragg moved to bar the indictment under the four-year limit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does OCGA § 17-3-2 (2) toll the statute when the crime is unknown?	State argues tolling applies from discovery of unknown crime.	Bragg asserts tolling only applies if the crime is unknown to the victim until a later date and not based on State knowledge.	Tolling not proven; limitation began Jan 1, 2010; indictment outside four years.

Harper v. State, 292 Ga. 557 (2013) (knowledge imputation for tolling purposes; standards applied)
Mullins, 321 Ga. App. 671 (2013) ( State must plead and prove tolling)
Moss v. State, 220 Ga. App. 150 (1996) (exception to statute must be alleged and proven)
Robins, 296 Ga. App. 437 (2009) (lack of knowledge of act, not merely illegality, tolling standard)
Jenkins v. State, 278 Ga. 598 (2004) (not tolled by routine investigation; evidence needed)
Womack v. State, 260 Ga. 21 (1990) (general tolling principles for criminal statutes)