The State v. Mathis, 338 Ga. App. 86

At ~2:30 a.m., Officer followed Justin Mathis after observing his vehicle; officer stopped Mathis asserting the license plate light was not illuminated in violation of OCGA § 40-8-23(d).
Officer testified he observed no working tag light from a gas-station vantage point, that the plate was not legible from 50 feet, and that Mathis acknowledged he would fix the light.
The officer’s dash-cam, his body-worn camera (with audio), and a still photo were admitted; defense introduced a still showing the tag illuminated from a vehicle-mounted light.
The trial judge expressed personal dislike for traffic stops based solely on a tag light, questioned the officer’s credibility, found the state did not prove an articulable suspicion, and granted the motion to suppress.
The State appealed, arguing the officer’s testimony and the recordings showed an unlit tag light and a lawful stop under the statute.
The Court of Appeals vacated the suppression order and remanded for reconsideration because the trial judge’s remarks suggested he may have applied his personal view of the statute rather than the correct legal standard.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Mathis)	Held
Whether officer had reasonable, articulable suspicion to stop for violation of OCGA § 40-8-23(d) (no tag light)	Officer observed no functioning tag light; exhibits and testimony show plate not legible from 50 feet	Officer’s plate was illuminated in recordings; officer lacked credibility	Trial court could reject officer’s testimony and grant suppression; appellate court deferred to credibility findings but vacated order for reconsideration due to judge’s comments
Whether the State met its burden to prove the stop lawful under OCGA § 17-5-30(b)	State met burden via officer testimony and camera evidence	Evidence contested; trial judge found burden unmet	Trial court was authorized to find the State failed its burden, but appellate court remanded for reconsideration consistent with proper legal test
Whether trial judge applied improper standard or personal bias in ruling	State: judge’s remarks reflected personal dislike but did not change legal analysis; ruling should stand if supported by credibility findings	Mathis: trial judge applied correct fact-finding and could discredit officer	Appellate court found judge acknowledged following law but his remarks suggested he may have imposed an incorrect test; vacated and remanded to ensure lawful application of statute

State v. Massa, 273 Ga. App. 596 (trial court bears burden to prove searches and seizures lawful)
State v. Allen, 298 Ga. 1 (appellate review must construe record in light most favorable to trial court fact findings)
State v. Able, 321 Ga. App. 632 (deference to trial court on credibility; no deference to legal conclusions)
Edenfield v. State, 293 Ga. 370 (less deference where facts ascertainable from video)
Tate v. State, 264 Ga. 53 (trial judge sits as trier of fact on suppression motions)
Tolbert v. State, 298 Ga. 147 (appellate deference requires viewing evidence in light favorable to trial court)
Hughes v. State, 296 Ga. 744 (trial court credibility determinations govern suppression rulings)