State v. Embert

Summary

The Supreme Court of Georgia vacated the trial court’s dismissal of the State’s case, holding that the December 2019 trial—despite the presence of an ineligible juror—was not void for speedy‑trial purposes and must be counted in the Barker‑Doggett analysis; the case was remanded for a new speedy‑trial determination. The Court distinguished Bowman and overruled Williams (1913) on the effect of an ineligible juror, and clarified that such a defect creates a voidable, not void, verdict.