Supreme Court of Georgia

Burns v. State

March 8, 2022313 Ga. 368

Summary

The Supreme Court of Georgia held that the 2016 amendments to OCGA §§ 17‑7‑52 and 45‑11‑4 are procedural, not substantive, and therefore apply to James Burns’s grand‑jury proceedings despite the underlying conduct occurring before the amendments; the Court also held that applying these procedural statutes does not violate the ex post facto prohibition. The Court affirmed the trial court’s denial of Burns’s motion to quash the indictment.