State v. Chapman

The trial court properly granted a new trial based on its determination that it erred in admitting testimony which was highly prejudicial to the defendant and did not have a sufficient connection to the defendant's alleged child molestation.

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After a jury found Laquaine Darryle Chapman competent to stand trial and another jury found Chapman guilty of two counts of aggravated child molestation and one count of child molestation, the trial court, acting sua sponte, declared a mistrial in the trial of Chapman’s guilt or innocence and ordered a new trial on the issue of his competency. On appeal, the State contends that the mistrial order is void because it was entered after the jury returned its verdict and that the trial court abused its discretion in ordering a new trial on the issue of Chapman’s competency. For reasons that follow, we conclude that the trial court, in substance, granted a new trial as to the issue of Chapman’s guilt or innocence, and that it did not abuse its discretion in doing so, thereby mooting the issue of whether the trial court erred in granting a new trial on the issue of Chapman’s competency to stand trial. Accordingly, we affirm.

The record shows that Chapman was indicted on two counts of aggravated child molestation and one count of child molestation. Chapman entered a special plea of incompetency to stand trial, and he demanded therein that the issue of his competency be resolved by a jury as set forth in OCGA § 17-7-130 b 2. After a jury found Chapman to be competent, another jury found him guilty on all counts in the criminal trial. At the conclusion of the criminal trial, the trial court stated, among other things, that “justice was not done in this courtroom this week,” and that the “process by which we reached the decision today . . . is hanging in my craw.” Approximately two weeks later, the trial court, acting sua sponte, entered contemporaneous orders granting a new trial on the issue of Chapman’s competency to stand trial and declaring a mistrial on the criminal charges.

State v. Chapman

The trial court properly granted a new trial based on its determination that it erred in admitting testimony which was highly prejudicial to the defendant and did not have a sufficient connection to the defendant's alleged child molestation.

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