Woods v. State
310 Ga. 358
| Ga. | 2020Background
- John Thomas Woods convicted of DUI (less safe), failure to maintain lane, and driving too fast for conditions.
- On appeal Woods argued his equal protection rights were violated because criminal cases use the lower expert-admissibility standard (OCGA § 24-7-707) rather than the civil standard (OCGA § 24-7-702).
- The Georgia Supreme Court noted it has previously rejected identical equal protection challenges (e.g., Mason; Mitchell).
- The Court held Woods’s equal protection claim merely reargues the correctness of prior decisions and thus does not invoke this Court’s appellate jurisdiction.
- The Court also found Woods’s remaining constitutional claims only involved application of well‑settled constitutional principles to facts—matters for the Court of Appeals—and transferred the appeal to the Court of Appeals.
- Justice Nahmias (joined by Justices Blackwell and Peterson) concurred, noting she would be inclined to grant certiorari to reconsider Mason if the Court of Appeals affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Equal protection re: expert‑testimony standards | Woods: using lower criminal admissibility standard violates equal protection | State: prior precedent upholds different civil/criminal standards; no constitutional defect | Court: lacks jurisdiction to revisit settled holdings; transfer to Court of Appeals |
| Other constitutional claims | Woods: various constitutional errors require review | State: these are applications of settled constitutional provisions to facts | Court: such claims fall within Court of Appeals jurisdiction; no Supreme Court jurisdiction |
| Availability of Supreme Court review | Woods seeks Supreme Court review now | State: procedural/jurisdictional rules control review route | Held: appeal transferred; certiorari remains available later (per concurrence) |
Key Cases Cited
- Mason v. Home Depot U.S.A., Inc., 283 Ga. 271 (rejected equal protection challenge to differing expert‑witness standards)
- Mitchell v. State, 301 Ga. 563 (extended prior summary rejection of similar equal protection claims to criminal defendants)
- State v. Turnquest, 305 Ga. 758 (disapproved part of Mitchell on other grounds)
- Zarate‑Martinez v. Echemendia, 299 Ga. 301 (Court lacks jurisdiction over constitutional challenges previously held constitutional against same attack)
- City of Decatur v. DeKalb County, 284 Ga. 434 (Court of Appeals has jurisdiction over applications of unquestioned constitutional provisions to facts)
- Pollard v. State, 229 Ga. 698 (quoted for jurisdictional principle regarding application of constitutional provisions to factual situations)