Livingston v. State

Blackburn, Judge.

Rupert Godfry Livingston appeals from the trial court’s ruling allowing the admission of his oral custodial confession over his objection based on the State’s violation of OCGA § 17-7-210. Livingston’s objection sought to exclude his oral custodial confession, a summary of which the State failed to timely provide pursuant to his request under former OCGA § 17-7-210.

Livingston was arrested at the Hartsfield International Airport for possession of marijuana on March 24, 1994. He was indicted on December 7, 1994, and arraigned on March 24, 1995. Counsel was appointed to…