GA: No reasonable expectation of privacy in jail mental health records

Defendant was behaving bizarrely in jail, so he was examined in the mental health section of the jail. He had a much diminished expectation of privacy in those records. When he filed a NGBRI defense, he waived it all. There was no Fourth Amendment violation by getting the records. Armstead v. State, 293 Ga. 243, 744 S.E.2d 774 (2013).

The officers had reasonable suspicion the defendant was patronizing a prostitute when they approached his car and talked to him. He was still free to leave when he was talking to them. Holmes v. State, 293 Ga. 229, 744 S.E.2d 701 (2013).*

Defendant’s stop was based on a concededly valid window tint violation, so his subjective intent to find drugs was irrelevant. The trial court’s findings the stop was not stalled were supported by the record. Walker v. State, 2013 Ga. App. LEXIS 478 (June 12, 2013).*

The traffic stop here was valid, and consent was obtained during the normal time of the stop. Defense counsel was not ineffective because any other ground of a motion to suppress would have been futile. Betancourt v. State, 322 Ga. App. 201, 744 S.E.2d 419 (2013).*