Supreme Court of Georgia

Budhani v. the State.

June 28, 2019830 S.E.2d 195

Summary

The court held that Budhani’s indictment was sufficient because it alleged that he sold or possessed with intent to distribute a specifically identified Schedule I controlled substance, and the statutory exceptions were affirmative defenses that the State need not plead. The court also held that promises of no additional charges can constitute an impermissible hope of benefit under the confession-voluntariness statute, but concluded that admitting Budhani’s statements was harmless because the evidence of guilt was overwhelming.