Stanley Randolph v. State

── Stanley Randolph v. State ── Court: Court of Appeals of Georgia Date: April 21, 2026 Category: General FIFTH DIVISION BROWN, C. J., RICKMAN, P. J., and MERCIER, J. NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules April 21, 2026 In the Court of Appeals of Georgia A26A0015. RANDOLPH v. THE STATE. RICKMAN, Presiding Judge. In this interlocutory appeal, Stanley Randolph contends that the trial court erred in denying his motion to suppress evidence obtained during what he alleges was an unlawful detention and search.1 For the reasons set forth below, we reverse. In determining whether a trial court properly denied a motion to suppress, appellate courts “must construe the evidentiary record in the light most favorable to the trial court’s factual findings and judgment.” Westbrook v. State, 308 Ga. 92, 96(2) (839 SE2d 620) (2020) (punctuation omitted). In addition, we generally must accept the trial court’s findings of disputed facts unless they are clearly erroneous, and also 1 We note that the State has failed to file a brief in this appeal. “generally must limit [our] consideration of the disputed facts to those expressly found by the trial court.” Hughes v. State, 296 Ga. 744, 746(1) (770 SE2d 636) (2015). But even though “we owe substantial deference to the way in which the trial court resolved disputed questions of material fact, we owe no deference at all to the trial court with respect to questions of law, and instead, we must apply the law ourselves to the material facts.” Id. at 750(2). Construed under the above standard, the record shows that at the motion to suppress hearing, Officer Fields with the Athens-Clarke County police department testified that he was on routine patrol in the Nellie B. Homes area at approximately 10:30 p.m. when he observed a Chrysler sedan backed into a parking space with its headlights illuminated. Officer Holcombe, also with the Athens-Clarke County police department, had seen the same vehicle parked in the same parking space, with its headlights illuminated, approximately one hour earlier. Both officers testified that they had previously responded to that area to investigate violent crimes and drug crimes and had recovered stolen vehicles in the cul-de-sac where the sedan was parked. They had also received complaints of people loitering by the cul-de-sac. 2  To investigate the situation, the officers drove their vehicles into the cul-de-sac, with their headlights pointing toward the sedan, and saw two males sitting in the front seats. Officer Fields testified that the males “both made furtive movements inside of the vehicle with their arms and then put their heads against the headrest.” Officer Holcombe testified that “[a]s we approached the vehicle, still in our vehicle, I could see males moving around. Appeared to be reaching down towards the floorboard of the vehicle.” The officers then exited their vehicles, approached the sedan and, after identifying the occupants, Officer Fields ran their names through a computerized record management system. The system flagged the driver, Randolph, as “known to carry a weapon,” and flagged the passenger, Carlos Perez, as “known to sell and use drugs, known to carry a weapon, and known to threaten police.” Officer Holcombe testified that, after hearing Perez’s name, he recalled information he had received about a man named Carlos distributing drugs in the area. He then contacted the source of the information, who was not sure of a last name for Carlos but did provide a physical description that matched Perez’s appearance.