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Hibbard v. State
Citations: 208 Ga. App. 457; 430 S.E.2d 824; 93 Fulton County D. Rep. 1547; 1993 Ga. App. LEXIS 601Docket: A93A0735
Court: Court of Appeals of Georgia; April 5, 1993; Georgia; State Appellate Court
Defendant Hibbard appeals his reckless driving conviction, focusing on the trial court's denial of his motion for a continuance. Hibbard's appointed counsel, who had represented him from July 1, 1991, until the trial's start on September 16, 1991, withdrew after Hibbard retained new counsel shortly before the trial. The retained counsel requested a continuance, citing inadequate preparation time, stemming from a disagreement Hibbard had with his appointed counsel just two days prior. The trial judge has discretion in granting continuances, and such requests are typically denied to prevent tactical delays by defendants. The appellate court found no abuse of discretion in the trial court's decision. It noted that Hibbard did not sufficiently demonstrate the nature of his disagreement with appointed counsel or justify the timing of his retained counsel's employment. Consequently, the trial court could reasonably infer that Hibbard was attempting to delay proceedings. The judgment of the trial court was affirmed, with Judges Beasley and Cooper concurring.