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State v. Woods

Both defendants had a reasonable expectation of privacy in the motel room in question and the safe where police found crack cocaine.

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The state appeals the grant of Adrian Woods and Katherine Lee’s motion to suppress. The state argues that neither Woods nor Lee had standing to object to the search of the motel room and the safe in which the police found cocaine; that as to Lee, the evidence should be admitted under the inevitable discovery rule; and that Woods validly consented to the searches at issue. We conclude that both Lee and Woods had a reasonable expectation of privacy in the room and the safe, so that they both have standing to object to the search. We find that the state cannot raise the inevitable discovery argument on appeal because it did not raise such an argument before the trial court. We also find that Woods’s consent was not valid. We therefore affirm the trial court’s grant of the motion to suppress. We accept a trial court’s ruling on disputed facts and credibility at a suppression hearing unless the ruling is clearly erroneous. See State v. Palmer , 285 Ga. 75, 79 673 SE2d 237 2009. Where the facts are not in dispute, we owe no deference to the trial court’s ruling and review the ruling de novo. Id.

Six police officers, including Officer Tommy Grier, the state’s only witness at the suppression hearing, went to a motel to execute a warrant for the arrest of Lee on aggravated assault charges. The officers went to the room listed on the warrant, but it was unoccupied. Officer Grier testified that the manager said that Lee was staying in Room 214. Neither Lee nor Woods, however, were on the registry for the room. In fact, the room was registered to Lee’s sister. At the hearing, the manager testified that he did not know whether Lee, a long-term resident of the motel, was staying in Room 214, but he suspected it.

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