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POWELL v. THE STATE (Two Cases)

2024-04-30

Summary

Holding. The trial court's order denying the general demurrers was reversed, and the indictment was found insufficient to withstand a general demurrer because the factual allegations, even if admitted as true, do not constitute the crimes charged.

Two former police officers, a former police chief and his former chief of staff, were indicted on charges of violating their oaths of office by allegedly failing to investigate other officers' misconduct in violation of Brady v. Maryland principles. The officers filed general demurrers arguing the indictment failed to adequately charge them with any crime under Georgia law. The trial court denied the demurrers, but the Georgia Supreme Court examined whether the indictment's specific factual allegations actually supported the charges as pleaded.

The court found that while the indictment technically recited the statutory elements of oath violation, the specific factual allegations—concerning failures to investigate and take administrative action—could not legally constitute Brady violations. Brady imposes no duty on prosecutors or police to investigate; it only restricts suppression of evidence already possessed. Because the officers could admit every fact alleged and still be innocent under the law, the indictment failed to state a valid crime.

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

Key issues

  • Sufficiency of indictment alleging oath-of-office violation based on Brady violations
  • Whether Brady imposes affirmative duty to investigate police misconduct
  • Whether indictment facts negate the legal elements of the crime charged

Procedural posture

The appellants appealed the trial court's denial of their general demurrers to an indictment charging violation of oath of office, and the case was transferred to the Georgia Supreme Court on constitutional question jurisdiction.

Authorities cited

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: April 30, 2024

S24A0239. POWELL v. THE STATE.

S24A0240. SCOTT v. THE STATE.

LAGRUA, Justice.

In these appeals—which have been consolidated for purposes

of issuing an opinion—we decide whether an indictment charging

two former police officers with violations of their oaths of office

under OCGA § 16-10-1 by failing to conduct investigations of other

police officers in purported violation of Brady v. Maryland, 373 U.S.

83 (83 SCt 1194, 10 LE2d 215) (1963), is sufficient to withstand the

general demurrers filed in the case below.1 For the reasons that

follow, we conclude that the indictment at issue is not sufficient to

withstand the general demurrers and violates federal constitutional

1 OCGA § 16-10-1 provides that “[a]ny public officer who willfully and

intentionally violates the terms of his oath as prescribed by law shall, upon

conviction thereof, be punished by imprisonment for not less than one nor more

than five years.”

due process, and thus, the trial court’s order denying the general

demurrers to the indictment should be reversed.

1. Appellant John Powell, formerly the Chief of Police of Glynn

County, and Appellant Brian Scott, formerly Powell’s Chief of Staff,

were indicted together in the Superior Court of Glynn County for

violation of their oaths as public officers for allegedly violating

Brady by failing to promptly investigate certain allegations of police

misconduct, failing to conduct an internal affairs investigation into

this alleged conduct, and/or failing to take other administrative

action related to this alleged conduct.2 Specifically, in Count 1 of the

2 On August 20, 2021, a Glynn County grand jury returned the

indictment against Powell and Scott, charging Powell with four counts of

violation of oath by a public officer (Counts 1 through 4) and Scott with one

count of violation of oath by a public officer (Count 1). Powell’s and Scott’s oaths of office are attached as exhibits to the indictment. Powell’s Oath of Office

states in pertinent part:

I, JOHN R. POWELL, do solemnly swear (or affirm) that I will

uphold the Constitution of the United States, the Constitution and

statutes of the State of Georgia, and the Ordinances of the County

of Glynn and that I will faithfully discharge my duties fairly and

impartially as a police officer and as the Chief of the Glynn County

Police Department. . . .

Scott’s Oath of Office states in pertinent part:

I do solemnly swear (or affirm) that I will uphold the [C]onstitution

of the United States, the Constitution and statutes of the State of

Georgia and the Ordinances of the County of Glynn. I will

faithfully discharge my duties fairly and impartially as a police

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indictment, Powell and Scott were jointly charged with “willfully

and intentionally” violating the terms of their oaths of office under

OCGA § 16-10-1 in the following manner:

in that they did fail to uphold the Constitution of the

United States, which provides in Article VII, Amendment

V, that no person shall be deprived of life, liberty, or

property without due process, as interpreted by the U.S.

Supreme Court in Brady v. Maryland, 373 U.S. 83 (83 SCt

1194, 10 LE2d 215) (1963), and the said accused, after

being shown a photograph of Glynn County Investigator

John Dustin Simpson of the Glynn/Brunswick Narcotics

Enforcement Team, hereinafter referred to as GBNET,

posing with Brian Highsmith, a convicted felon for

Possession With Intent to Distribute Methamphetamine,

and being informed that John Dustin Simpson and Brian

Highsmith maintain a close personal relationship, and

said relationship being a violation of GBNET and Glynn

County Police Department, . . . fail[ing] to promptly

investigate said allegations and fail[ing] to timely conduct

an Internal Affairs investigation of said allegations. . . .

In Count 2 of the indictment, Powell was individually charged with

“willfully and intentionally” violating the terms of his oath of office

under OCGA § 16-10-1 in the following manner:

in that he did fail to uphold the Constitution of the United

States, which provides in Article VII, Amendment V, that

no person shall be deprived of life, liberty, or property

without due process, as interpreted by the U.S. Supreme

officer of Glynn County, so help me God. . . .

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Court in Brady v. Maryland, 373 U.S. 83 (83 SCt 1194, 10

LE2d 215) (1963), and the said accused, after being

notified by the Camden County Sheriff, Jim Proctor, that

Glynn/Brunswick Narcotics Enforcement Team officers,

hereinafter referred to as GBNET, were working

undercover drug investigations in Camden County,

Georgia without any legal authority to conduct said

investigations, . . . fail[ing] to initiate an Internal Affairs

investigation into said conduct and [] fail[ing] to take any

administrative action in regard to the GBNET personnel

involved in Camen County. . . .

In Count 3 of the indictment, Powell was individually charged with

“willfully and intentionally” violating the terms of his oath of office

under OCGA § 16-10-1 in the following manner:

in that he did fail to uphold the Constitution of the United

States, which provides in Article VII, Amendment V, that

no person shall be deprived of life, liberty, or property

without due process, as interpreted by the U.S. Supreme

Court in Brady v. Maryland, 373 U.S. 83 (83 SCt 1194, 10

LE2d 215) (1963), and the said accused, after being

notified by McIntosh County Sheriff, Steve Jessup, that

Colonel Danny Lowe of the McIntosh County Sheriff’s

Office had been stopped and detained by Glynn County

law enforcement officers with the assistance of

Glynn/Brunswick Narcotics Enforcement Team officers,

hereinafter referred to as GBNET, on two different

occasions and under questionable circumstances, . . .

fail[ing] to initiate an Internal Affairs investigation into

said traffic stop and [] fail[ing] to identify the GBNET

officers involved in said traffic stop, and [] fail[ing] to take

any administrative action against any personnel involved

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in said traffic stop. . . .

In Count 4 of the indictment, Powell was individually charged with

“willfully and intentionally” violating the terms of his oath of office

under OCGA § 16-10-1 in the following manner:

in that he did fail to uphold the Constitution of the United

States, which provides in Article VII, Amendment V, that

no person shall be deprived of life, liberty, or property

without due process, as interpreted by the U.S. Supreme

Court in Brady v. Maryland, 373 U.S. 83 (83 SCt 1194, 10

LE2d 215) (1963), and the said accused, after being

notified that Glynn/Brunswick Narcotics Enforcement

Team officers, hereinafter referred to as GBNET, were

working as law enforcement officers in the State of

Florida, without any legal authority to do so, and that the

GBNET officers requested a Glynn County Police Officer

Kevin Yarborough to effect a traffic stop on a specific

vehicle, and later requested that the Glynn County Police

Officer Kevin Yarborough omit from his official report

involving a fatality that GBNET officers had fact initiated

the traffic stop, . . . fail[ing] to initiate an Internal Affairs

investigation into the conduct of the GBNET officers and

[] fail[ing] to take any administrative action against any

personnel involved. . . .

In November 2021, Powell and Scott each filed a general

demurrer to the indictment,3 asserting, among other things, that the

3 At the same time, Powell and Scott also filed special demurrers to this

indictment, as well as separate statutory demands for speedy trial pursuant to

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indictment (1) “fails to adequately charge [Powell and Scott] with

any offense against the laws of the State of Georgia;” (2) does not

form “the bases for a felony criminal offense and therefore cannot be

conduct amounting to a violation of [their] oath of office;” and (3)

“fails to set forth any description of the way the alleged conduct of

the accused. . . violates the United States Constitution as

interpreted by the U.S. Supreme Court in Brady v. Maryland.”

Powell and Scott also asserted that the oath-of-office statute, OCGA

§ 16-10-1, was “unconstitutionally vague” as applied to the facts of

this case.

At the hearing on the general demurrers, Powell and Scott

OCGA § 17-7-170. The special demurrers were denied by the trial court and

are not before us on appeal. As for the speedy-trial demands, in October 2022,

Powell and Scott filed motions to dismiss the indictment, seeking to be

discharged and acquitted of all charges because they were not tried during the

September 2021 term of court or the next term of court, which began in March

2022 and ended in September 2022. In November 2022, the trial court held a

hearing on the motions to dismiss and subsequently denied the motions. In

denying the motions, the trial court determined, among other findings, that

Powell and Scott failed to serve the assigned judge with their speedy-trial

demands and that OCGA § 17-7-170 (a) “specifically requires a defendant [to]

serve his speedy-trial demand on both the prosecutor and the judge to whom

the case is assigned.” The trial court concluded that, “[b]ecause Powell and

Scott failed to strictly comply with the statute, they made no demand for

speedy trial,” and their motions should be denied.

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argued that the indictment should be dismissed because they could

admit all the facts alleged therein and not be guilty of any crimes.

To that end, Powell and Scott again argued that the indictment fails

to allege any facts constituting a crime; fails to allege any conduct

amounting to a Brady violation; and fails to identify a particular

case or a particular defendant whose case has been affected by a

Brady violation or whose federal constitutional rights have been

violated. The State argued that “[t]here were numerous cases of

people denied their liberty” or “denied their life” by the acts and/or

omissions of Powell and Scott, but the State did not identify any such

cases. In response, Powell and Scott reiterated that the State had

failed to specify any pending criminal cases that had allegedly been

impacted by a Brady violation on their part, and they argued that

their federal due process rights would be violated if the State was

allowed “to stray from the terms of the indictment” by prosecuting

them based upon cases, actions, or incidents that were not included

in the indictment.

The trial court denied the general demurrers, concluding that,

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if Powell and Scott were to admit the allegations in the indictment,

the “admission of these allegations would constitute conduct

violative of the oaths of office taken by [Powell and Scott]” and

further determining that, even if “the underlying conduct charged

was not per se criminal under Georgia law, . . . the conduct alleged,

if proven true, would constitute conduct not only grossly

inconsistent with that imposed upon [Powell and Scott] by their

oaths, but also going to the very heart of the obligations they

assumed when they took their oaths.” 4

2. We review a trial court’s ruling on a general demurrer “de

novo in order to determine whether the allegations in the indictment

are legally sufficient.” State v. Mondor, 306 Ga. 338, 341 (1) (830

4 Citing Poole v. State, 262 Ga. 718, 719 (425 SE2d 655) (1993), the trial

court also concluded that OCGA § 16-10-1 was “not unconstitutionally vague

as applied to Powell and Scott” and denied their general demurrers on this

additional ground. Powell and Scott appealed the trial court’s ruling—

including the trial court’s conclusion that OCGA § 16-10-1 was not

unconstitutionally vague as applied to the facts of this case—to the Court of

Appeals. In their appeals, Powell and Scott also sought review of the trial

court’s denial of their motions to dismiss the indictment on speedy-trial

grounds. After observing that these appeals invoked our Court’s constitutional

question jurisdiction, the Court of Appeals transferred the appeals to this

Court in October 2023.

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SE2d 206) (2019) (citation and punctuation omitted). Having done

so, we agree with Powell and Scott that the trial court’s ruling

regarding the sufficiency of the indictment was erroneous, and their

general demurrers should have been granted.

“As a general matter, a demurrer (whether general or special)

must allege some flaw on the face of the indictment itself,” and “a

court cannot go beyond the four corners of the indictment in

considering a demurrer.” State v. Williams, 306 Ga. 50, 53 (2) (829

SE2d 117) (2019). See also Bullard v. State, 307 Ga. 482, 486 (2) n.5

(837 SE2d 348) (2019) (noting that “the trial court could not look

beyond the four corners of the indictment in considering [the

defendant’s] demurrer”).

To assess the merits of a general demurrer, which

challenges the sufficiency of the substance of the

indictment, a court asks whether the defendant can admit

each and every fact alleged in the indictment and still be

innocent of any crime. If so, the general demurrer should

be sustained. But if the admission of the facts alleged

would lead necessarily to the conclusion that the accused

is guilty of a crime, the indictment is sufficient to

withstand a general demurrer.

Williams, 306 Ga. at 52 (2) (citation and punctuation omitted;

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emphasis in original). Framed another way, this Court has held

that, if an indictment “recite[s] the language of the statute that sets

out all the elements of the offense charged or allege[s] the facts

necessary to establish a violation of a criminal statute, then the

indictment is sufficient to withstand a general demurrer.” Mondor,

306 Ga. at 341 (1) (citing Jackson v. State, 301 Ga. 137, 141 (1) (800

SE2d 356) (2017)).

Here, the indictment lays out the elements of the statutorilydefined crime of violation of oath of office by a public officer. See

OCGA § 16-10-1 (“[a]ny public officer who willfully and intentionally

violates the terms of his oath as prescribed by law shall, upon

conviction thereof, be punished by imprisonment for not less than

one nor more than five years.”). The indictment also specifies which

term of the oath of office Powell and Scott allegedly violated—their

obligation “to uphold the Constitution of the United States”—and

which specific provision thereof—Article VII, Amendment V of the

United States Constitution as interpreted by the United States

Supreme Court in Brady v. Maryland, 373 U.S. 83 (83 SCt 1194, 10

10

LE2d 215) (1963). As such, the indictment satisfies the general

demurrer standard as set forth in Mondor and Jackson insofar as it

“recite[s] the language of the statute that sets out all the elements

of the offense charged.” Mondor, 306 Ga. at 341 (1). See also

Jackson, 301 Ga. at 139 (1) (“[T]o withstand a general demurrer, an

indictment must . . . recite the language of the statute that sets out

all the elements of the offense charged[.]”).

However, under these circumstances, if the indictment here

only recited “the language of the statute that sets out all the

elements of the offense charged”—and therefore satisfied the

general demurrer standard, Mondor, 306 Ga. at 341 (1)—the

indictment would not be sufficient to withstand a special demurrer,

which “challenges the sufficiency of the form of the indictment.”

Kimbrough v. State, 300 Ga. 878, 880 (2) (799 SE2d 229) (2017)

(citation and punctuation omitted; emphasis in original). “By filing

a special demurrer, the accused claims . . . that the accused is

entitled to more information.” Id. at 880-881 (2) (citation and

punctuation omitted). When considering an indictment under a

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special demurrer challenge,

[w]e have held that an indictment not only must state the

essential elements of the offense charged, but it also must

allege the underlying facts with enough detail

to sufficiently apprise the defendant of what he must be

prepared to meet. As we have explained, when a court

considers whether an indictment is sufficient to

withstand a special demurrer, it is useful to remember

that a purpose of the indictment is to allow a defendant

to prepare her defense intelligently.

Id. at 881 (2) (citations and punctation omitted; emphasis supplied).5

Applying those principles here, the indictment at issue charges

Powell and Scott with “willfully and intentionally” violating the

terms of their oath of office under OCGA § 16-10-1 by failing to

uphold the due process clause of the United States Constitution as

interpreted by Brady. Brady stands for the proposition that “the

suppression by the prosecution of evidence favorable to an accused

upon request violates due process where the evidence is material

5 Here, it appears that the State reindicted Powell and Scott after the

trial court granted special demurrers on the first indictment for a lack of

sufficient underlying facts, resulting in the indictment presently at issue. The

first indictment is not part of the record in this case; however, the procedural

history of that indictment was referenced at the general demurrer hearing in

January 2022.

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either to guilt or to punishment, irrespective of the good faith or bad

faith of the prosecution.” Brady, 373 U.S. at 87. This Court has

explained that Brady “does not require the pre-trial disclosure of

exculpatory evidence,” Davis v. State, 261 Ga. 382, 385 (8) (b) (405

SE2d 648) (1991) (citation omitted; emphasis supplied), and does not

impose a duty upon the State to investigate. See Brown v. State, 250

Ga. 66, 74 (6) (295 SE2d 727) (1982); Hines v. State, 249 Ga. 257,

258-259 (1) (290 SE2d 911) (1982); Baker v. State, 245 Ga. 657, 661-662 (3) (266 SE2d 477) (1980); Rini v. State, 236 Ga. 715, 718 (4)

(225 SE2d 234) (1976); Hicks v. State, 232 Ga. 393, 394-395 (207

SE2d 30) (1974). We have held that, for a criminal defendant to

establish a Brady violation, the following four factors must be met:

(1) the State possessed evidence favorable to [the

accused’s] defense; (2) [the accused] did not possess the

favorable evidence and could not obtain it himself with

any reasonable diligence; (3) the State suppressed the

favorable evidence; and (4) had the evidence been

disclosed to the defense, a reasonable probability exists

that the outcome of the trial would have been different.

Davis v. State, 316 Ga. 418, 425 (4) (c) (888 SE2d 546) (2023)

(citation and punctuation omitted).

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As explained above, to withstand a general demurrer in this

case, the State was not required to allege any additional facts in the

indictment beyond the statutory elements of OCGA § 16-10-1, but

the State generally must allege additional facts to survive a special

demurrer. Here, the State alleged additional facts, but those facts—

namely, that Powell and/or Scott violated the terms of their oaths of

office by committing Brady violations through their failures to

investigate and undertake the administrative actions alleged in

Count 1 through 4 of the indictment—are inconsistent with the

criminal statute as pleaded and negate the manner in which Powell

and Scott purportedly violated the terms of their oaths of office. In

other words, here, the indictment alleges that Powell and Scott

committed these crimes in a specific way. If Powell and Scott admit

to that, they are still innocent of the alleged crimes because it is

legally impossible to commit the crimes in the way the State alleged

in the indictment.

When we review the sufficiency of an indictment, “we read the

indictment as a whole.” Sanders v. State, 313 Ga. 191, 196 (3) (a)

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(ii) (869 SE2d 411) (2022). We most often rely on this principle to

uphold an indictment where one count does not include sufficient

details, but those details are provided in other counts of the

indictment. See id. (determining that an indictment survived a

demurrer because, although the conspiracy count of the indictment

failed to identify a co-conspirator or overt act in furtherance of the

conspiracy, “the alleged deficiencies [were] addressed” in another

count of the indictment). See also State v. Wyatt, 296 Ga. 257, 260-261 (1) (b) (759 SE2d 500) (2014) (observing that “[w]e will consider

each felony murder count and its underlying felony count together,

and examine whether the entirety of the indictment provides

sufficient detail about the crimes [the defendant] is accused of

committing” so as to put the defendant on notice of what he will have

to defend against at trial). However, here, this principle leads us to

conclude that, where the details provided in each count actually

negate the elements of the crimes charged, the indictment is not

sufficient to withstand a general demurrer because Powell and Scott

“can admit each and every fact alleged in the indictment and still be

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innocent of” the crimes alleged by the State. Williams, 306 Ga. at

52 (2). And, although we have not articulated this specific rule

before, it is consistent with our case law.

Accordingly, in this case—even assuming (without deciding)

that a Brady violation could form the basis of a violation of oath of

office charge—the facts as alleged in this indictment do not support

such a charge because Powell’s and Scott’s purported failures to

investigate and undertake the administrative actions alleged in

Counts 1 through 4 of the indictment are not Brady violations. 6 See

Davis, 261 Ga. at 385 (8) (b). See also Mondor, 306 Ga. at 341 (1).

We thus conclude that the indictment against Powell and Scott

“cannot withstand a general demurrer,” Mondor, 306 Ga. at 341 (1)

(citation and punctuation omitted), and therefore, the trial court’s

denial of Powell’s and Scott’s general demurrers to the indictment is

6 Although we must accept all factual allegations as true, the State’s

allegations that this conduct violated Brady are conclusions of law, which we

are not required to accept. See Wyatt, 295 Ga. at 267-268 (3) (“[I]n reviewing

demurrers, the allegations in the indictment are taken as true[.]”) (citing Lowe

v. State, 276 Ga. 538, 539 (579 SE2d 728) (2003) (explaining that the court

must take the allegations in the indictment as true when evaluating a

demurrer)).

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reversed. And, because we have concluded that this indictment

cannot withstand a general demurrer, we need not reach Powell’s

and Scott’s constitutional challenge or the speedy-trial issue also

before us on appeal. 7

Judgment reversed. All the Justices concur.

7 See Cottrell v. Smith, 299 Ga. 517, 520 (I) (A) (788 SE2d 772) (2016)

(“[I]t is well-settled that this Court will not decide a constitutional question if the decision in the appeal can be made on other grounds.”) (citing Deal v.

Coleman, 294 Ga, 170, 171 n.7 (751 SE2d 337) (2013)).

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