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Brown v. State

Defendant's payment of a fine for a seat belt violation did not bar her prosecution for additional charges arising out of the same accident because her fine was designated as a cash bond which was held in the court's registry.

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Natasha Renee Brown appeals the trial court’s denial of her plea in bar of procedural double jeopardy, claiming that her payment of a fine for a seat belt violation prevents the State from pursuing additional charges arising from a 1998 car accident. ” ‘The appellate standard of review of a grant or denial of a double jeopardy plea in bar is whether, after reviewing the trial court’s oral and written rulings as a whole, the trial court’s findings support its conclusion.’ ” Wilson v. State.1

The facts show that on July 17, 1998, Natasha Renee Brown was involved in a car accident that resulted in the death of her nine-year-old nephew. The police cited Brown for failing to secure a minor, requiring her to appear on August 20, 1998 at a hearing in the traffic division of Clayton County State Court. This hearing date was continued by agreement of counsel because the State was investigating the possibility of bringing additional charges in connection with the crash.

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