Meadows v. State

The evidence was insufficient to support defendant's misdemeanor escape conviction, because a reasonable person would have thought that the detention was temporary given that defendant was not handcuffed, confined or transported.

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A Chattahoochee County jury found Dwayne Meadows guilty of felony obstruction,1 misdemeanor obstruction,2 misdemeanor escape,3 and two counts of terroristic threats.4 On appeal, Meadows contends that the trial court erred in denying his motion for a directed verdict of acquittal on the charges of felony obstruction, misdemeanor obstruction, and escape. Finding that the evidence was sufficient to support the jury’s verdict as to felony and misdemeanor obstruction, we affirm. However, Meadows’s conduct of resisting the lawful pat-down and leaving the scene is insufficient to support a conviction for escape. Viewed in a light most favorable to the jury’s verdict,5 the evidence shows that a concerned citizen called 911 to report that a man had been firing a gun and was on Highway 26. The information was relayed to Sheriff Glenn Cooper and Chief Deputy Ronald Hoard, who were advised to be on the lookout for a black male dressed in dark clothing and carrying a plastic bag. The Sheriff drove to Highway 26, where he and the Chief recognized Meadows, with whom they were familiar, walking down the road and carrying a plastic bag.

The Chief asked Meadows what was going on. Meadows, who was sweating and upset, responded that he had broken up with his girlfriend, and that “I’m fed up with all this God damn f___ing bull___ between me and my girlfriend.” The Chief exited the car and “charged him at that time for disorderly conduct . . . and asked him if I could search.” Because the Chief had received information about a gun, he placed Meadows against the car, searched his bag, and then began to pat Meadows down for weapons. Meadows elbowed the Chief before he could complete the pat-down, causing the Chief to lose his balance. Meadows ran away into the woods and then out of sight of the Chief, who tried to follow as the Sheriff fired a warning shot into the air.

Meadows v. State

The evidence was insufficient to support defendant's misdemeanor escape conviction, because a reasonable person would have thought that the detention was temporary given that defendant was not handcuffed, confined or transported.

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