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Mobleyv.The State

CourtSupreme Court of Georgia
Docket No.S18G1546
DecidedOctober 21, 2019
Reporter307 Ga. 59
JudgesSupreme Court of Georgia
Tags
CriminalCriminal LawCriminal ProcedureFourth AmendmentSearch and SeizureDigital EvidenceEvidenceReversal
Case Summary

After a collision killed two people, investigators downloaded electronic data from the airbag-control module in Victor Mobley’s vehicle without a warrant. The data indicated that Mobley had been traveling at nearly one hundred miles per hour. Officers obtained a warrant the next day to seize the modules, but did not retrieve additional data after executing it. Mobley was convicted of vehicular homicide and moved to suppress the warrantless download. The trial court admitted the evidence under inevitable discovery, and the Court of Appeals affirmed. The Georgia Supreme Court reversed. It held that the State had not established the factual foundation required for inevitable discovery. The later warrant authorized seizure of the modules, but the State did not show that investigators would inevitably have obtained the already-downloaded data through a lawful process. The Court also rejected reliance on a good-faith exception because the officers had not relied on binding appellate precedent. The evidence should have been suppressed, and the case returned for proceedings consistent with the ruling.

Opinion

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