Middleton v. State

Summary

The Supreme Court of Georgia vacated the Court of Appeals’ decision and remanded the case to the trial court, directing it to clarify whether its suppression ruling was based on a factual finding that Officer Graw’s deputization was limited to particular cases. The Court held that the scope of a deputy sheriff’s authority is a question of fact subject to deferential review, and therefore the trial court must determine the nature of the 2013 deputization before deciding the legality of the search.