Georgia v. Bryant
Annotate this CaseA grand jury indicted Archie Bryant and Jose Carrillo in connection with the 2017 shooting death of Shawn Rhinehart. The indictment charged Bryant with malice murder, two counts of felony murder, two counts of aggravated assault, and possession of a firearm by a convicted felon. Bryant elected to proceed under reciprocal discovery. The State brought an interlocutory appeal of the trial court’s order to exclude certain evidence on the basis that the evidence was not produced until just over a month before trial, or had not been produced at all, in violation of the trial court’s pre-trial scheduling order. The trial court’s order could stand only if it properly found the State acted with bad faith and that defendant was prejudiced as a result. The Georgia Supreme Court determined the trial court’s order was ambiguous both as to whether the court actually found bad faith on the part of the State at all and as to the basis for the trial court’s finding of prejudice to the defendant. Accordingly, the Supreme Court vacated the trial court’s ruling and remanded for the trial court to clarify its ruling on the defendant’s motion to exclude the evidence.
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