Sunday, November 16, 2014

Examples of Work

Below is an example of a Case Brief and Motion to Suppress that I drafted. These drafts were done as an assignment in a paralegal class or for work purposes. Both of the following are documents I have drafted to be submitted based off the particular circumstances of the case at hand.


EXAMPLE 1: CASE BRIEF


Name of Case and Citation: Kringle v. Elliott, 301 Ga. App. 1, 686 S.E.2d 665 (2009).


Procedural History:

The mother, Norma Kringle, filed a lawsuit on behalf of her son, Steven Lloyd, against their neighbor, Cindy Elliott, for the injuries the child received when he was bitten by Elliott’s golden retriever. Elliott also filed a motion in limine that excluded evidence about past behavior of the dog. Elliott filed a motion for directed verdict saying that under the “first bite” rule there was no cause of action and the trial court granted this motion. Kringle, the mother, appealed this decision to the Georgia Court of Appeals.

Statement of Facts:

Steven Lloyd the son of Norma Kringle went into the backyard of their neighbor Cindy Elliott. Elliott’s backyard was often frequented by children from the neighborhood. Elliott was the owner of a golden retriever named Skip. The dog was kept on a chain in Elliott’s fenced in backyard. Lloyd went into Elliott’s backyard to play with other children from the neighborhood. Lloyd was jumping on the trampoline for a while before he decided that he wanted to go over and pet the dog. At the time a little girl was in Elliott’s backyard playing with the dog. Lloyd said that he thought the dog “looked nice” and that is why he wanted to go over and pet it. When Lloyd approached the dog and reached out to pet it the dog jumped on him and bite him.

            During the trial Elliott testified that there had been a previous time when she had seen her dog running around with something in its mouth. Although Elliott thought the dog had a toy in its mouth it was actually a dead kitten. Elliott was unsure whether the dog had killed the kitten since it did not have any puncture marks on its body. Elliott did not know if the kitten was dead before the dog found it or if the dog was just retrieving like his breed tends to do. Elliott also testified that she had a previous discussion with her neighbor who was moving. The neighbor told Elliott of when she had seen Elliott’s dog playing in her backyard with her sickly puppy. After the dogs had been playing the sick puppy ended up dying. The neighbor said they had expected the puppy to die because of its sickness but that she wondered if Elliott’s dog may have killed the puppy. The neighbor was not sure though because there were no bite marks on the puppy and she had seen the dogs playing in the backyard. The neighbor’s son ended up taking the dog back into Elliott’s backyard. Lloyd also testified saying that he had never seen the dog be mean to anyone prior to when he was bitten.
Issues:

1) Whether the past behavior of the dog having been in situations where a puppy and kitten both ended up dying proved that the dog had the potential to act in an aggressive manner.

2) Whether the dog owner, Elliott, had knowledge that her dog, Skip, had the propensity to bite someone prior to Steven Lloyd being bitten.

Answers/Holdings:
1) No. There was nothing to prove without a doubt that the dog had harmed or injured either the puppy or kitten because there were no bite marks on either of the animals and no one had seen the dog attack either animal, the information only created an assumption that the dog could have possibly caused the harm to the animals.
2) No. Elliott could not have been aware that her dog might potentially bite someone because it was never known whether the dog killed the puppy or kitten therefore she had no reason to believe that her dog may cause harm, under the “first bite” rule Elliott cannot be considered liable for the damages that were caused to Steven Lloyd because of a lack of knowledge.
Reasoning:
Under the “first bite” rule the owner must have knowledge that the dog has the propensity to bite someone. Kringle v. Elliott, 301 Ga. App. 1, 686 S.E.2d 665 (2009). This rule does not require the dog to actually bite a person first. It may be enough to prove that an incident occurred which would cause a sensible person to expect their dog to act in a way that could injure someone. A dog attacking another animal may be enough to prove the type of temperament of the dog creating awareness of the dog’s potential to bite. While a previous attack would not necessarily be required, at least some sort of menacing behavior would be. Kringle v. Elliott, 301 Ga. App. 1, 686 S.E.2d 665 (2009). In order for evidence to be considered relevant it has to prove or disprove a material fact that’s at issue in the case. The evidence in this case only created a presumption that the dog had previously caused harm to the puppy or kitten. There is no evidence, however, establishing that the harm was caused by vicious attack rather than the overzealous play of a large dog. Kringle v. Elliott, 301 Ga. App. 1, 686 S.E.2d 665 (2009). Since there was no proof of an actual attack occurring the trial court did not err in granting a motion in limine excluding the evidence about the other animals.   
 The only evidence that may have indicated the dog’s propensity to bite was speculative at best, as no one saw the dog attack the puppy or the kitten, neither of which had bark marks, and there was no other indication that the dog had ever bitten or attacked another animal. Kringle v. Elliott, 301 Ga. App. 1, 686 S.E.2d 665 (2009). Since the evidence was at best an educated guess of what happened it could not prove that the dog had the tendency to behave in a way that could cause harm to others nor give any reason for Elliott to have knowledge that the dog may attempt to bite someone. Considering that the evidence did not show that the dog had previously attacked an animal or human there was no way that Elliott would have thought her dog would behave viciously and bite a person. A dog owner will be liable for damages only if the owner has knowledge that the dog has the propensity to do the particular act (biting) which caused injury to the complaining party. Kringle v. Elliott, 301 Ga. App. 1, 686 S.E.2d 665 (2009). Without Elliott having any knowledge of the dog’s propensity to bite there is no cause of action under the “first bite” rule. Elliott was entitled to a directed verdict judgment and could not be held liable for any of the damages that were caused to Lloyd when he was bitten by Elliott’s golden retriever.  
Decision/Disposition:
The Court of Appeals affirmed the decision of the trial court to grant Elliott’s motion for directed verdict.

 

EXAMPLE #2: MOTION TO SUPPRESS

IN THE SUPERIOR COURT OF _______ COUNTY
STATE OF GEORGIA

THE STATE OF GEORGIA,                     *

            Plaintiff,                                             *          CRIMINAL ACTION FILE NO.:

                                                                        *         
v.                                                                     *         

                                                                        *

______________,                                           *         

            Defendant.                                         *

 

MOTION TO SUPPRESS

          COMES NOW, the Defendant, ______, and files this her Motion to Suppress pursuant to the Fourth, Fifth and Fourteenth Amendments to the Constitution of the United States; Article 1, Section 1, Paragraph I (due process), Paragraph XIII (search and seizure), Paragraph XVI (self-incrimination) of the Constitution of the State of Georgia; O.C.G.A. § 17-5-30; O.C.G.A. § 17-4-20; O.C.G.A. § 17-4-23 and other statutory and case law  and in further support thereof shows this Honorable Court the following:

1.
            On or about August 25, 2014, the Defendant was driving a car on Main Street in Athens-Clarke County, Georgia.
2.

            Without a warrant, and without probable cause or individualized articulable suspicion that any laws had been violated, police authorities with the Athens-Clarke County Sheriff’s Office stopped, waylaid and detained the Defendant.
3.
            Said agents for the State of Georgia also conducted a search of the Defendant herein without probable cause. After illegally stopping, waylaying and detaining the Defendant herein, authorities illegally searched the Defendant’s vehicle, and questioned the Defendant.
4.
            The above-stated stop, even if deemed valid, was followed by search and seizure beyond any explicit or implicit authorization attendant to the stop.
5.
            Said stop, search and seizure were illegal and any evidence ostensibly seized as a result of the illegal stop followed by the illegal search and seizure would be fruits of Federal and State Constitutional violations. This includes any observations, statements, or blood samples obtained subsequent to the unlawful stop, search, or seizure.
6.
            Said conduct was illegal and violative of the protection provided by the Fourth Amendment to the Constitution of the United States as well as not within any of the exceptions enumerated in O.C.G.A. § 17-5-1, nor any exception for so-called “constitutionally permissible suspicionless searches.”
7.
            Any purported waiver of Fourth Amendment of purported rights under the Constitution of the State of Georgia was insufficient as any search waiver was not freely, voluntarily, and knowingly given. Further, any purported “consent” or waiver was the product of an illegal detention and mere acquiescence in the face of police authority and therefore invalid.
8.
            Said search, seizure and arrest were violative of the Fourth, Fifth and Fourteenth Amendments to the Constitution of the United States; Article 1, Section 1, Paragraph I (due process), Paragraph XIII (search and seizure), Paragraph XVI (self-incrimination) of the Constitution of the State of Georgia; O.C.G.A. § 17-4-20, O.C.G.A. § 17-4-20, O.C.G.A. § 17-5-30 and other statutory and case authority.
9.
            Defendant respectfully reserves the right to amend this Motion to Suppress should more information become available and/or as the law and facts of the case require

            WHEREFORE, Defendant prays that this Honorable Court set this matter down for a hearing and upon consideration of same grant the Motion to Suppress and exclude from evidence any and all evidence purportedly seized in conjunction with the illegal and violative search and seizure, including, but not limited to the following:
            (a) any evidence seized as a result of illegal arrest, detention, search and seizure;

(b) any derivative evidence obtained as a result of the illegal arrest, search and seizure; and

(c) any statements purportedly made by Defendant herein in which Defendant was not Mirandized and/or other statements which were derivative of other illegal police conduct herein.

            Respectfully submitted this _____ day of _______________, 20__.

 

_______________________
Attorney’s Name
Attorney for Defendant

Georgia Bar No.:

 

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