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There was, however, a significant risk that denying the motion would be manifestly unfair to Odum.” Remanded with direction to appoint conflict counsel. Note, the “conflict” here arises from defendant’s federal lawsuit filed against the public defenders – which would not create a conflict if filed against the judge, see Savage v. State, 263 Ga.App. 180, 587 S.E.2d 294 (September 11, 2003); Carter v. State, 259 Ga.App. 798, 578 S.E.2d 508 (February 21, 2003). Nothing in the opinion indicates any assessment of the merits of the civil action. Requiring conflict counsel upon the mere filing of a civil action seems to allow the defendant to engage in the very dilatory tactics the Court of Appeals warns about: “A defendant could indefinitely delay trial by filing a federal lawsuit against every attorney appointed to represent him.” Compare Smith v. State , 274 Ga.App. 568, 618 S.E.2d 182 (July 26, 2005) (Defendant effectively rejected counsel by filing bar complaints against two appointed attorneys in succession, and by then proceeding pro se without seeking further appointment of counsel). III. BONDS A. APPEAL BONDS See POST-CONVICTION RELIEF – APPEALS BOND/INCARCERATION/ Edvalson v. State, S15A1869, ___ Ga. ___, ___ S.E.2d ___, 2016 WL 856812 (March 7, 2016). In child pornography prosecution, pretrial habeas petition properly denied. State sought to revoke defendant’s bond based on violation of condition that he have no “internet enabled” devices in his home; rather than revoking the bond, however, the court imposed additional restrictions. Held, 1. no violation of Due Process resulted: “Edvalson had clear notice that the originally-imposed bond conditions, and his alleged violation of those conditions, were at issue with the possible sanction of the complete revocation of his bond. Even in the situation of a complete revocation of bond, only minimal due process is required prior to the revocation. Camphor v. State, [272 Ga. 408, 410(2)(b), 529 S.E.2d 121 (2000)]. Edvalson’s bond was not revoked and he was not deprived of his freedom by incarceration; indeed, he prevailed in the State’s attempt to revoke his bond. Furthermore, he had a full and fair opportunity to be heard before his bond was modified. In the revocation proceeding, the superior court had the authority to impose additional reasonable restrictions on Edvalson’s behavior as conditions of his pretrial release on bond. Id. ” 2. Conditions were reasonable. “As the habeas court noted, the conditions of bond detailed by the superior court at the revocation hearing merely reflected and clarified the preventive nature of the special conditions of the original bond order in light of the new evidence regarding Edvalson’s conduct. Indeed, the additional conditions did not constitute unanticipated restrictions at all; they merely helped to effectuate the goal of the special conditions as stated in the original bond order. The plain purpose of the special conditions, from inception, was to prevent Edvalson from having access to children, images of children, and the internet for the purpose of creating, obtaining, promoting, or disseminating child pornography. This reflects the State’s compelling interest, ‘in safeguarding the physical and psychological well-being of minor children by protecting them from being subjects of pornography, which is obviously harmful to [their] psychological, emotional, and mental health.’ (Quotation marks omitted.) Bennett v. State, 292 Ga.App. 382, 384(1), 665 S.E.2d 365 (2008), quoting Aman v. State, 261 Ga. 669, 670(1)(b), 409 S.E.2d 645 (1991). The special conditions of bond as summarily set forth in the initial bond order would ill-serve this compelling public safety interest if Edvalson could engage in the criminal conduct sought to be prohibited by merely doing so outside of the confines of his home. Thus, the special conditions imposed in this case were appropriate and reasonable under the facts, and therefore, do not constitute an abuse of the superior court’s discretion.[fn] Camphor v. State, supra at 410–411(2)(b), 529 S.E.2d 121.” Alden v. State, 314 Ga.App. 439, 724 S.E.2d 451 (February 29, 2012). In prosecution for DUI and related offenses, trial court properly denied plea in bar based on double jeopardy; home confinement and other bond conditions didn’t constitute punishment barring further prosecution. After defendant failed to appear for two court dates, he was arrested on bench warrant. Defendant was then allowed to post new bond, pursuant to which he “was placed on home confinement, had an ignition interlock device placed on his vehicle, was required to wear a ‘Secure Continuous Remote Alcohol Monitor’ (‘SCRAM device’), and was required to submit to a drug and alcohol evaluation and to follow any treatment recommendations.” “Considering the nature of Alden's arrest and charges, we conclude that the amount and conditions of his bond—home confinement, drug and alcohol evaluation and counseling, installation of an ignition interlock device on his vehicle, and a SCRAM bracelet—were not punishment for purposes of double jeopardy, but instead ‘are rationally related to an alternative purpose as they are designed to prevent [Alden] from being a danger to the community by committing future acts of driving under the influence while [he] was awaiting trial’ and to assure Alden's presence at court proceedings,” quoting Strickland v. State, 300 Ga.App. 898 (686 S.E.2d 486) (2009). Schaff v. State, 304 Ga.App. 638, 697 S.E.2d 305 (June 28, 2010). In defendant’s prosecution for child molestation and LOCATION, below B. CONDITIONS

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