Sisson v. StateSisson v. State
Defendant was tried before a jury and found guilty of driving under the influence of alcohol (“DUI”) in violation of
At that point, defendant was placed under arrest and read his implied consent warnings. Mullins came to the scene and took custody of defendant’s 14-year-old son.
The jury found defendant guilty as charged on each count. Defendant’s direct appeal to the Supreme Court of Georgia was determined to “involve the application and not the construction and interpretation of the Georgia Constitution, [and so] this case [was] transferred to the Court of Appeals.” Held:
1. Defendant first contends he was denied equal protection under Art. I, Sec. I, Par. II of the 1983 Georgia Constitution, arguing that “[p]ursuant to
(a) “There are three standards generally accepted for determining constitutionality under the Equal Protection Provisions of both the U. S. and [Georgia] Constitutions: (1) The rational relationship test; (2) The intermediate level of scrutiny; and (3) The strict judicial scrutiny standard.” (Citation and punctuation omitted.)
McDaniel v. Thomas,
(b) “Under this analysis, . . . statutory classifications are presumed valid and will survive an equal protection challenge if the classification bears a rational relationship to a legitimate government interest.
McDaniel,
In our view, defendant cannot meet either prong of this test. He conceded he “has perfectly good hearing,” and so he is not similarly situated to hearing-impaired DUI suspects who, in the absence of a translator, are not interrogated or read their implied consent warnings for up to one hour. Secondly, “[t]he intent of
2. Next, defendant contends he was denied the right to confront his accuser, as guaranteed by the Sixth Amendment to the U. S. Constitution and Art. I, Sec. I, Par. XIV of the 1983 Georgia Constitution. In this regard, he complains of the admission into evidence of State’s Exhibit 1, which is the Georgia Bureau of Investigation Certificate of Inspection for “breath testing instrument, [serial number] 68-001337.” Attached to this certificate are printouts purporting to be the test results from the inspection as performed by Trooper R. M. Webb, the signatory to the certificate. Defendant argues “the test results should not have been tendered in the trial as evidence along with the certificate required by
At trial, defendant interposed objections based on hearsay, denial of cross-examination of Trooper Webb, and best evidence. Officer Turney was then permitted to offer foundation evidence. He testified he knew R. M. Webb is a state trooper; that Trooper Webb is the implied consent area supervisor whose duty it is to “go around to all of our Intox machines and to inspect them and calibrate them and make sure they are working properly”; that “Trooper Webb run[s] a test on the machine when he inspects it quarterlyt; and that] he [ran] a test on the machine when he inspected it on January 2nd, 1996.” Officer Turney identified the attachments to the inspection certificate as “[a] printout of the machine and the test that Trooper Webb ran on it.”
In our view, this was an adequate foundation to admit the printouts as business records under
3. In the third enumeration, defendant contends the trial court erred in admitting evidence of a prior incident of driving under the influence of alcohol. Relying on
Old Chief v. United States,
In
Old Chief,
that defendant was charged with a violation of
(a) Thus, in
Old Chief,
that defendant’s proposed stipulation amounted to an admission against his penal interest because it established an element of the subsequently charged crime. Our Supreme Court has recently reached the same result as
Old Chief
(independent of that decision’s analysis) with respect to a charge of possession of a firearm by a convicted felon.
Robinson v. State,
(b) Moreover, the interpretation of
In Georgia, the admission of evidence, including questions of relevancy, is a matter committed to the sound legal discretion of the trial court.
Baker v. State,
In the case sub judice, we find no error in the trial court’s implicit determination that defendant’s prior DUI was more probative than prejudicial. “Evidence of a prior DUI offense, regardless of the circumstances surrounding its commission, is logically connected with a pending DUI charge as it is relevant to establish that the perpetrator has the bent of mind to get behind the wheel of a vehicle when [it is] less safe for him to do so.” (Citations and punctuation omitted.)
McCullough v. State,
Under Georgia law,
Miranda
warnings must precede a request to perform a field sobriety test only when the suspect is “in custody.”
Price v. State,
“For the proscriptions of
Miranda v. Arizona,
[supra,] to apply, £a person must have been taken into custody or otherwise deprived of his freedom of action in some significant way.’
Lobdell v. State,
In our view, defendant was not in the custody of the police as that phrase has been construed.
Trudewind v. State,
Judgment affirmed.
Notes
Since the prior DUI in the case sub judice was relevant only as similar transaction evidence and not for impeachment, it is the circumstance of driving with an unlawful blood alcohol concentration rather than any conviction that is logically connected to the subse
quently charged crime. “It is not essential for admissibility that the similar crime resulted in a conviction. [Cits.]”
Green v. State,