Glispiev.State
Jaylend Glispie challenged his convictions after police pursued a vehicle, arrested him near the vehicle’s registered owner’s home, and recovered drugs and two cell phones from his person. At trial, the State introduced text messages sent to one of the phones and relied on them as admissions. The Supreme Court of Georgia granted certiorari to decide whether the messages were admissible as party admissions and whether the trial court properly denied Glispie’s motion in limine. The Court held that the messages were admissible because the State presented sufficient circumstances connecting Glispie to the phone and the messages, and the trial court did not abuse its discretion in admitting them. The Court also rejected the remaining evidentiary challenge, but it reversed one part of the Court of Appeals’ reasoning concerning the scope of the trial court’s ruling and affirmed the judgment in the other respects. The opinion distinguished a search of a cell phone supported by a warrant from the warrantless cell-phone search addressed in later Supreme Court precedent. The judgment was affirmed in part and reversed in part. All the Justices concurred.
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