Williams v. GeorgiaAnnotate this Case
“If the trial court has made express findings of fact, but not with sufficient detail to permit meaningful appellate review, an appellate court may remand for further findings.” Michael Williams was indicted for burglary and obstruction of justice by fleeing. He appealed, arguing the trial court erred in denying his motion to suppress certain evidence. The trial court made almost no express findings of fact before denying the motion. Given the uncertainty in the trial court’s order regarding the basis for its ruling, the Georgia Supreme Court vacated the opinion of the Court of Appeals which upheld the trial court’s judgment, and remanded for the Court of Appeals to remand this case to the trial court for further clarification on the specific findings that formed the basis for its legal conclusions with regard to Williams’ motion to suppress.