LAW.coLAW.co

Bowman v. State

2023-02-21

Summary

Holding. The Georgia Supreme Court reversed the Court of Appeals' judgment, holding that a proceeding conducted before unsworn citizens does not satisfy the statutory requirement of a "trial" under Georgia's speedy trial statute, and therefore Bowman's discharge and acquittal was properly granted.

Logan Bowman was indicted in February 2014 for crimes against his daughter and properly demanded a speedy trial under Georgia law in September 2014. A proceeding in December 2014 took place before 12 citizens selected for jury duty, but the court never administered the oath required by Georgia law to constitute them as a sworn jury. The trial court later granted Bowman's motion for discharge based on speedy trial grounds, finding that more than five years had passed without a valid trial. The Court of Appeals reversed, holding that the December 2014 proceeding satisfied the speedy trial statute even without the jury oath.

The Georgia Supreme Court reversed the Court of Appeals and reinstated Bowman's discharge and acquittal. The court held that administration of the jury oath is an essential prerequisite to a legally valid jury trial and that without the oath, there is no jury and therefore no trial. Because the December 2014 proceeding involved unsworn citizens rather than a sworn jury, it did not constitute a "trial" under Georgia's speedy trial statute. Bowman was therefore entitled to discharge and acquittal because he was not brought to trial within the required timeframe.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether administration of the jury oath is required for a valid criminal trial
  • Whether an unsworn group of 12 citizens constitutes a "jury" under Georgia law
  • Whether a proceeding before unsworn citizens satisfies the statutory speedy trial requirement
  • The meaning of "trial" and "tried" in Georgia's speedy trial statute

Procedural posture

The trial court granted Bowman's motion for discharge and acquittal on speedy trial grounds; the Court of Appeals reversed; and the Georgia Supreme Court granted certiorari and heard oral arguments before rendering its decision.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: February 21, 2023

S22G0303. BOWMAN v. THE STATE.

BOGGS, Chief Justice.

In February 2014, a Paulding County grand jury indicted

Logan Adam Bowman for crimes against his daughter. At the next

term of court, Bowman properly invoked his right to a speedy trial

pursuant to the applicable speedy trial statute, OCGA § 17-7-170.

More than five years later, the State still had not brought him to

trial before 12 citizens sworn by the court or the court clerk to “well

and truly try the issue formed upon this bill of indictment . . . and a

true verdict give according to the evidence,” OCGA § 15-12-139, so

Bowman filed a motion for discharge and acquittal on speedy trial

grounds, which the trial court granted. The State appealed, and in

State v. Bowman, 361 Ga. App. 465 (863 SE2d 180) (2021), the Court

of Appeals reversed, holding that a “trial” by an unsworn group of

citizens satisfies the requirements of OCGA § 17-7-170. We granted

Bowman’s petition for certiorari and now reverse the Court of

Appeals’ judgment. 1

1. On August 30, 2013, the Paulding County Sheriff’s Office

arrested Bowman on suspicion of child molestation and incest.

Almost six months later, on February 17, 2014 – during the January

2014 term of the Paulding County Superior Court – the grand jury

indicted Bowman on one count of aggravated child molestation, six

1 The trial court granted Bowman’s motion for discharge and acquittal

on both statutory and constitutional speedy trial grounds. See OCGA § 17-7-170 (b) (“If the defendant is not tried when the demand for speedy trial is made

or at the next succeeding regular court term thereafter, provided that at both

court terms there were juries impaneled and qualified to try the defendant, the

defendant shall be absolutely discharged and acquitted of the offense charged

in the indictment or accusation. . . .”); U.S. Const. amend. VI (“In all criminal

prosecutions, the accused shall enjoy the right to a speedy . . . trial, by an

impartial jury . . . .”); Ga. Const. of 1983, Art. I, Sec. I, Par. XI (a) (“In criminal cases, the defendant shall have a . . . speedy trial by an impartial jury; and the jury shall be the judges of the law and the facts.”). The Court of Appeals

reversed the trial court’s order granting the motion, rejecting both Bowman’s

statutory and constitutional claims. In light of our conclusion that the trial

court correctly granted Bowman’s motion under the applicable speedy trial

statute, we need not separately address the Court of Appeals’ treatment of

Bowman’s constitutional claims. See State v. Bell, 274 Ga. 719, 720 (559 SE2d

477) (2002) (concluding that the defendant’s constitutional speedy trial claim

was moot once this Court held that he was entitled to discharge and acquittal

under the applicable speedy trial statute).

2

counts of child molestation, and two counts of incest. On September

18, during the July 2014 term, Bowman filed a Demand for Speedy

Trial pursuant to OCGA § 17-7-170 and an Assertion of

Constitutional Right to Speedy Trial. 2

Later during the July 2014 term, starting on December 1, the

trial court held a proceeding at which the parties selected 12 citizens

from among those summoned for jury service to try Bowman’s case.

However, neither the court nor the court clerk administered the jury

oath required by OCGA § 15-12-139, which says:

In all criminal cases, the following oath shall be

administered to the trial jury: “You shall well and truly

try the issue formed upon this bill of indictment (or

accusation) between the State of Georgia and (name of

accused), who is charged with (here state the crime or

offense), and a true verdict give according to the evidence.

So help you God.” The judge or clerk shall administer the

oath to the jurors.

Instead, on the morning of December 2, the court gave preliminary

instructions, the parties made opening statements, and the State

2 The Paulding County Superior Court has two regular terms of court

each year, one starting the second Monday in January, and the other starting

the second Monday in July. See OCGA § 15-6-3 (31.1).

3

called its first witness. On December 3, the State rested, and

Bowman called the first of two witnesses. Bowman himself did not

testify. On December 4, the parties made closing arguments, the

court gave a jury charge, and before noon, the 12 citizens retired to

deliberate.

On December 5, after deliberating for more than a day, the

unsworn group of 12 citizens purported to return verdicts acquitting

Bowman on seven of the nine counts of the indictment and finding

him guilty beyond a reasonable doubt of one count each of child

molestation and incest. On December 30, the court held a sentencing

hearing and sentenced Bowman to a total term of 50 years in prison

with the first 15 years to be served in confinement and the

remainder to be served on probation. Bowman filed a timely motion

for new trial.

More than four years later, at a status conference on March 7,

2019, Bowman requested the appointment of conflict counsel, and

the court granted his request. Conflict counsel filed an amended

motion for new trial arguing, among other things, that the complete

4

failure to administer the jury oath was a structural error that

required setting aside the verdicts, Bowman’s judgment of

conviction, and his sentence. At a hearing, the State informed the

court that it had investigated the matter and determined that the

jury oath was never administered to the 12 citizens who purported

to decide Bowman’s case. The court entered a consent order setting

aside the verdicts, Bowman’s judgment of conviction, and his

sentence and reinstating his case to active status on the court’s trial

calendar.

On November 27, 2019, through new counsel, Bowman filed a

motion for discharge and acquittal on statutory and constitutional

speedy trial grounds. On the same day, the State filed a motion

seeking a declaratory order that the December 2014 proceeding

“constitute[d] a trial” for the purpose of satisfying Bowman’s

Demand for Speedy Trial pursuant to OCGA § 17-7-170 and the

speedy trial provisions of the Sixth Amendment to the United States

Constitution and the Georgia Constitution. The court held an

evidentiary hearing at which Bowman presented evidence that

5

juries were impaneled and qualified to hear cases at the July 2014

term of court, the January 2015 term of court, and the nine

succeeding terms of court since then. On March 30, 2020, the court

entered an order granting Bowman’s motion for discharge and

acquittal, relying on this Court’s decisions in Slaughter v. State, 100

Ga. 323 (28 SE 159) (1897), and Spencer v. State, 281 Ga. 533 (640

SE2d 267) (2007). Two days later, the court ordered Bowman’s

immediate release after more than six-and-a-half years in custody.

The State appealed, and on October 5, 2021, the Court of

Appeals issued an opinion reversing the trial court’s order granting

Bowman’s motion for discharge and acquittal. The Court of Appeals

acknowledged that Bowman properly invoked his right under OCGA

§ 17-7-170 to be tried no later than the January 2015 term of court.

See Bowman, 361 Ga. App. at 466. However, citing dictionary

definitions of the word “trial,” the Court of Appeals held that

“Bowman was ‘tried’ or placed on ‘trial’ within the plain meaning” of

OCGA § 17-7-170 at the December 2014 proceeding. Id. at 472. The

Court of Appeals also rejected Bowman’s speedy trial claim based on

6

the Sixth Amendment to the United States Constitution and the

Georgia Constitution. See id. at 473-475.

We granted Bowman’s petition for certiorari and posed the

following question:

Was [Bowman] deprived of his statutory or constitutional

right to a speedy trial where the trial he received was held

before a jury that had not sworn the oath required by

OCGA § 15-12-139?

The case was orally argued in this Court on September 20, 2022.

2. The dispute in this case centers on the meaning of the

words “trial” and “tried” in OCGA § 17-7-170. Subsection (a) of

OCGA § 17-7-170 says:

Any defendant against whom a true bill of indictment or

an accusation is filed with the clerk for an offense not

affecting the defendant’s life may enter a demand for

speedy trial at the court term at which the indictment or

accusation is filed or at the next succeeding regular court

term thereafter . . . .

Subsection (b) then says:

If the defendant is not tried when the demand for speedy

trial is made or at the next succeeding regular court term

thereafter, provided that at both court terms there were

juries impaneled and qualified to try the defendant, the

7

defendant shall be absolutely discharged and acquitted of

the offense charged in the indictment . . . . 3

In interpreting statutes, we “presume that the General

Assembly meant what it said and said what it meant.” Deal v.

Coleman, 294 Ga. 170, 172 (751 SE2d 337) (2013) (citation and

punctuation omitted).

[A]nd so, we must read the statutory text in its most

natural and reasonable way, as an ordinary speaker of the

English language would. The common and customary

usages of the words are important, but so is their context.

For context, we may look to other provisions of the same

statute, the structure and history of the whole statute,

and the other law – constitutional, statutory, and common

law alike – that forms the legal background of the

statutory provision in question.

Zaldivar v. Prickett, 297 Ga. 589, 591 (774 SE2d 688) (2015)

(citations and punctuation omitted). Thus, “[w]e construe statutes

in connection and in harmony with the existing law, and as a part of

a general and uniform system of jurisprudence.” In the Interest of

3The remaining subsections of the statute specify when a demand for

speedy trial expires, how the statute applies when a jury returns a verdict but

the judgment is reversed on appeal, how the statute applies when a case ends

in a mistrial, and how the statute applies when the defendant files a special

plea of incompetency to stand trial or the court conducts a trial on the

competency of the defendant. See OCGA § 17-7-170 (c) - (f).

8

M. D. H., 300 Ga. 46, 53 (793 SE2d 49) (2016) (citation and

punctuation omitted).

Here, the Court of Appeals erred in failing to give proper

weight to the constitutional background of the applicable speedy

trial statute and this Court’s precedents. The “speedy trial” that

criminal defendants charged with noncapital crimes have the right

to demand under OCGA § 17-7-170 (a) is the same “speedy trial” that

is guaranteed by the Sixth Amendment to the United States

Constitution and the Georgia Constitution. U.S. Const. amend. VI

(guaranteeing “right to a speedy . . . trial, by an impartial jury,” in

all criminal prosecutions); Ga. Const. of 1983, Art. I, Sec. I, Par. XI

(a) (guaranteeing that “[i]n criminal cases, the defendant shall have

a . . . speedy trial by an impartial jury”). See Durham v. State, 9 Ga.

306, 309 (1851) (stating that statutory predecessor to OCGA § 17-7-170 “was wisely and humanely framed to carry into effect that

provision of the Constitution which declares, that ‘in all criminal

prosecutions, the accused shall enjoy the right to a speedy and public

trial’”). OCGA § 17-7-170 provides a mechanism that criminal

9

defendants may employ to ensure that their constitutionally

guaranteed right to a speedy trial is not violated. See Denny v. State,

6 Ga. 491, 493 (1849) (“This law puts it in the power of the accused

to compel a trial, as early as the second term of the Court after the

bill is found, in cases not capital . . . .”).

More than 125 years ago, this Court held that administration

of the jury oath now codified at OCGA § 15-12-139 is an

indispensable prerequisite to a legally valid jury trial. See Slaughter

v. State, 100 Ga. 323, 324 (28 SE 159) (1897) (“It is essential to the

legality of any criminal trial that there should be a lawfully

constituted tribunal; and where such tribunal is composed in part of

a jury . . . how can the tribunal be considered as lawfully constituted

unless the jurors actually take this oath, either literally or in

substance?”). We held in Slaughter that because no attempt had

been made to comply with the jury oath statute, “there was no trial

at all, because there was no lawful jury. It was, in effect, no more

than a trial by a mob . . . .” Id. at 324-325. We further explained that

“[w]here . . . the requirements of the statute as to administering an

10

oath to a jury trying a criminal case have been utterly ignored,”

there is a jurisdictional defect in the proceedings, because “there

must be a lawful tribunal; and where the trial is by jury, it must be

legally constituted, or it will be without authority to pass upon the

issues submitted.” Id. at 326.

Put differently, the administration of the jury oath is what

turns the 12 citizens selected to hear a criminal case into a jury

invested with the authority to decide whether the accused is guilty

of a crime. Without the oath, there is no jury; and without the jury,

there is no trial. See id. at 329 (“‘A jury is a body of [citizens]

summoned and sworn to decide upon the facts in issue at the trial.

Hence, [citizens] summoned as jurors must also be sworn before they

constitute an organized and competent tribunal to which the issues

in a cause can be submitted for trial.’” (citation omitted)). See also

Martinez v. Illinois, 572 U.S. 833, 839-840 (134 SCt 2070, 188 LE2d

1112) (2014) (“Jeopardy attaches when a defendant is ‘put to trial,’

and in a jury trial, that is when a jury is empaneled and sworn.”

(citation and some punctuation omitted; emphasis added). A

11

proceeding conducted before 12 citizens who have not taken the jury

oath is nothing more than an “attempted trial,” Spencer v. State, 281

Ga. 533, 535 (640 SE2d 267) (2007), which does not satisfy the

requirements of OCGA § 17-7-170.

The Court of Appeals’ holding that the December 2014

proceeding constituted a “trial” at which Bowman was “tried” for

purposes of OCGA § 17-7-170 cannot be squared with this Court’s

decisions in Slaughter and Spencer. Accordingly, we reverse the

judgment of the Court of Appeals.

Judgment reversed. All the Justices concur, except Pinson, J.,

disqualified.

12