State v. Bell

Benham, Justice,

dissenting.

I respectfully dissent to the majority’s affirmance of the trial court’s grant of the defendant’s motion for an absolute discharge and acquittal of the murder charges pending against him. Given the extreme nature of the sanction of absolute discharge and acquittal, it can only be invoked when there has been strict compliance with OCGA §§ 17-7-170 and 17-7-171, the statutes which prescribe the means by which a criminal defendant may assert the right to speedy trial after indictment. Patten v. State, 250 Ga. App. 498, 499 (552 SE2d 110) (2001); Hanson v. State, 196 Ga. App. 589 (1) (396 SE2d 510) (1990). I do not believe the document which defendant Bell relies upon as a demand for trial is in strict compliance with the minimum acceptable standard for asserting the statutory right to a speedy trial. Furthermore, I believe it is time for this Court to finish the task begun 20 years ago in State v. Adamczyk, 162 Ga. App. 288 (290 SE2d 149) (1982), when Judge Banke undertook to “discourage th[e] type of draftmanship” through which attorneys seek to use a variety of requests, demands and motions as valid demands for trial filed pursuant to OCGA §§ 17-7-170 and 17-7-171.

1. OCGA § 17-7-171 requires a defendant to enter a “demand for *721trial.” In the case at bar, defendant Bell did not enter a demand-, rather, he filed a motion in which he requested a trial by jury in the next two terms. See attached copy. “A ‘request’ is not a ‘demand.’ [Cit.] The use of the term ‘request’ instead of ‘demand’ cannot ‘reasonably be construed’ to demand a speedy trial. . . .” Bennett v. State, 244 Ga. App. 149 (1) (534 SE2d 881) (2000) (a document in which the defendant “requests a jury trial pursuant to OCGA § 17-7-170” failed to meet the minimum acceptable standard for asserting the defendant’s right to a speedy trial). Furthermore, the use of the caption, “Motion to Set Trial,” on the document in which defendant Bell purportedly demanded a speedy trial does not set out “the exact nature of the pleading,” as required by Uniform Superior Court Rule 36.3.

[T]he recipient of a document captioned as a [“Motion to Set Trial”] will not necessarily attribute to it the same “exact nature” as would be attributed to a document captioned as a “DEMAND FOR TRIAL.” A written [motion to set trial] is not analogous to a demand for trial pursuant to OCGA § 17-7-170 [or § 17-7-171]. . . . The caption does not set “out the exact nature” of the pleading as containing an additional demand by [Bell] for a speedy trial pursuant to OCGA § 17-7-17[l].

Kramer v. State, 185 Ga. App. 254, 255-256 (363 SE2d 800) (1987). Consequently, the motion may not serve as a demand for speedy trial pursuant to OCGA § 17-7-171. Id.1

2. In 1982, Judge Banke made a laudable effort in State v. Adamczyk to bring an end to the seemingly unending litigation concerning the specificity of a demand for trial that could result in statutory discharge and acquittal. He was, however, unable to close the door completely on the subject, as evidenced by the two decades of litigation which have ensued. While “substantial compliance” with either of the statutes authorizing the filing of a demand for speedy trial is insufficient to trigger discharge and acquittal (Patten v. State, supra, 250 Ga. App. at 499), and appellate case law requires that the caption of the pleading in which the demand for speedy trial is made contain “the exact nature of the pleading” before discharge and acquittal occur (Kramer v. State, supra, 185 Ga. App. 254), the appellate courts have been reluctant to adopt a hard and fast rule as to what constitutes a demand for speedy trial sufficient to permit dis*722charge and acquittal should the demand not be honored. The Adamczyk court declined to require any particular form, deeming a pleading sufficient if it “[could] reasonably be construed as a demand for trial under the [statutory] provisions. . . .” 162 Ga. App. at 290. Over the last twenty years, the variety of appellate determinations of what “[could] reasonably be construed as a demand for trial under the [statutory] provisions” has led us back to the confusion the Adamczyk court faced. Accordingly, I believe it is time we resort to requiring that a valid demand for speedy trial be couched in a particular form. Such a form would require that the demand be contained in a pleading containing no other subject matter, that the pleading be captioned DEMAND FOR SPEEDY TRIAL PURSUANT TO OCGA § 17-7-170 or § 17-7-171 (whichever is applicable), and that the pleading contain the style of the case and the case number or indictment number in which it is being filed. The use of these standards, it is hoped, will make the filing of a demand for speedy trial more of an administrative process rather than one requiring a judicial imprimatur.

In sum, defendant Bell’s “Motion to Set Trial” does not qualify under current appellate case law as a valid demand for speedy trial so as to entitle the pleader to automatic discharge and acquittal of the murder charge for which he was indicted, and the trial court’s ruling to the contrary should be reversed. Accordingly, I dissent to the majority’s affirmance of the trial court’s ruling. To avoid this type of litigation in the future, the Court should hold that a statutory demand for speedy trial will not be valid unless the pleading in which it is contained meets the standards set forth above.

I am authorized to state that Justice Hines joins this dissent.

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*723Decided February 4, 2002. Paul L. Howard, Jr., District Attorney, Advera A. Wheeler, Assistant District Attorney, for appellant. J. Robert Joiner, for appellee.

As an example of the reason why our trial courts have rules requiring a pleading’s caption to reflect the exact nature of the pleading, I note that the superior court clerk’s office describes the motion in the index of the case record as a “Letter Requesting Trial by Jury. Filed June 26.1996.”