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method he used to commit the crime. Also, this is not a case in which the issues of Grant’s intent or identity as the perpetrator were resolved in his favor by a prior acquittal, which would have barred introduction of evidence concerning those issues. See Salcedo v. State, 258 Ga. 870, 376 S.E.2d 360 (1989); Lucas v. State, 178 Ga.App. 150, 342 S.E.2d 377 (1986).” Reversed on other grounds, 272 Ga. 213, 528 S.E.2d 512 (March 13, 2000). Jones v. State, 236 Ga.App. 330, 511 S.E.2d 883 (February 9, 1999). At defendant’s trial for armed robbery, evidence of a crack pipe found in defendant’s vehicle was properly admitted as part of the res gestae without compliance with similar transaction rules. “‘ Evidence discovered in [defendant’s vehicle], implicating him in [an uncharged drug offense], was evidence of the res gestae and as such is expressly excluded from the procedural requirements applicable to separate but similar crimes. [USCR] 31.3(E); Grace v. State, 262 Ga. 746, 747(1), 425 S.E.2d 865 (1993). Substantively, the State is entitled to present evidence of the entire res gestae and such evidence is not rendered inadmissible despite the fact that the character of the accused is incidentally implicated. Chambers v. State, 250 Ga. 856, 859(2), 302 S.E.2d 86 (1983).’ Galbreath v. State, 213 Ga.App. 80, 83(3), 84, 443 S.E.2d 664 (1994).” 11. EXCLUSIONARY RULE, APPLICABILITY Betancourt v. State, 322 Ga.App. 201, 744 S.E.2d 419 (June 12, 2013). Conviction for cocaine trafficking affirmed; trial court properly admitted similar transaction evidence. Contrary to defendants’ argument, exclusionary rule doesn’t apply to similar transaction evidence of traffic stop made in another state; thus, State here wasn’t required to prove that evidence obtained in “the North Carolina traffic stop was the product of a lawful search and seizure.” “[I]t is unlikely that the application of the exclusionary rule here would deter illegal searches and seizures in Georgia to any appreciable degree. Indeed, the notion of there being any meaningful deterrent effect from applying the exclusionary rule in a Georgia criminal proceeding as a result of evidence unlawfully obtained by law enforcement in a foreign jurisdiction is fanciful at best. To be sure, every law-enforcement officer in Georgia is armed with the knowledge that the manner in which he or she conducts a search will ‘affect the prosecution's ability to secure a conviction in a criminal trial,’ and this knowledge significantly deters the use of unlawful searches and seizures in our state. [ State v. Thackston, 289 Ga. 412, 413(1) (716 S.E.2d 517) (2011).] But there is no reason to assume that applying the exclusionary rule to evidence stemming from the unlawful acts of a law-enforcement officer from a foreign state will do anything to advance the rule's remedial objectives here in Georgia. Cf. id. at 415–16(1) (applying the balancing test to hold that the exclusionary rule does not apply to probation revocation hearings); see also Pennsylvania Bd. of Probation & Parole v. Scott, 524 U.S. 357, 363–69(II) (118 S.Ct. 2014, 141 L.Ed.2d 344) (1998) (exclusionary rule does not apply to parole revocation hearings); I.N.S. v. Lopez– Mendoza, 468 U.S. 1032, 1040–50(IV) (104 S.Ct. 3479, 82 L.Ed.2d 778) (1984) (exclusionary rule not applicable in civil deportation proceedings); United States v. Janis, 428 U.S. 433, 447–60(IV) (96 S.Ct. 3021, 49 L.Ed.2d 1046) (1976) (no exclusionary rule in civil tax proceedings); United States v. Calandra, 414 U.S. 338, 349–52(IV) (94 S.Ct. 613, 38 L.Ed.2d 561) (1974) (exclusionary rule does not apply in grand-jury proceedings). Thus, because the rule's deterrence benefits are so clearly outweighed by the costs of withholding the similar-transaction evidence from the truth-seeking process, the trial court did not err in admitting the subject evidence in this case.” Affirmed on other grounds, sub nom. Hernandez v. State , 294 Ga. 903, 757 S.E.2d 109 (March 28, 2014) (“Because Hernandez has failed to preserve any error with respect to the suppression of the similar transaction evidence, it is not necessary in this case to consider the extent to which the exclusionary rule applies to similar transaction evidence obtained as a result of a search and seizure by out-of- state law enforcement officers. Accordingly, we express no opinion about the correctness of the views of the Court of Appeals upon that subject.”). 12. GENERALLY Peoples v. State, 295 Ga. 44, 757 S.E.2d 646 (April 10, 2014). Felony murder and related convictions affirmed; trial court erred, but harmless, in admitting similar transaction evidence of defendant’s involvement in another armed robbery and shooting without notice and hearing pursuant to USCR 33.1 and 31.3(A). 1. Contrary to State’s argument, evidence of the prior armed robbery was similar transaction evidence. State contends that the prior crime, which occurred just 12 days before the offenses on trial and involved the same handgun, was part of the same sequence of events and offered the evidence “to prove Appellant's identity. Because the State maintained that the evidence was not similar transaction evidence, it had not provided notice of its intention to offer the evidence as required by Uniform Superior Court Rules 31.1 and 31.3(A). … The trial court agreed with the State's position, ruling that the evidence was ‘not a similar transaction, but evidence of the crime charged.’ However, Appellant was not charged with the Buckhead robbery in this case. Evidence about the Buckhead robbery was extrinsic to the crimes charged; it did not bear directly on Appellant's alleged conduct in this case, nor was it intrinsic to, or inextricably intertwined with, the crimes at the McClure house. See generally Paul S. Milich, Georgia Rules of Evidence § 11:3 (2012–2013

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