Evans v. State

Deen, Presiding Judge.

The burden on appeal is always on the appellant to show both error and injury. Quackenbush v. Quackenbush, 230 Ga. 649 (1-a) (198 SE2d 851). While it is error to fail to rule on a timely written motion to suppress evidence (Amiss v. State, 135 Ga. App. 784, 785 (219 SE2d 28)) an oral motion, not meeting statutory requirements, may be disregarded, and the motion should be presented prior to trial. In this record, after the jury was impaneled but before evidence was introduced, defendant’s counsel urged the court to rule on the motion to suppress among others "discussed in…