Appeals Court Dismisses Pending Charges Against Men Convicted of Concealing Georgia Teacher’s Death

FITZGERALD, Ga.—An appellate court has dismissed pending criminal charges against two men who had previously been convicted for concealing the death of Georgia teacher Tara Grinstead, whose disappearance in 2005 puzzled her family and authorities for over a decade.

On Thursday, the Georgia Court of Appeals ruled that the statute of limitations had lapsed by the time prosecutors in Ben Hill County brought charges against the men related to the incineration of Grinstead’s body in a rural pecan orchard nearly 20 years ago.

The prior convictions in the case remain intact. In 2022, Ryan Duke was found guilty in Irwin County, where Grinstead resided, for concealing her death but was acquitted of murder. His friend, Bo Dukes, who shares a similar surname, was convicted of covering up the crime in 2019. Both are currently serving time in prison.

Grinstead, a 30-year-old high school teacher and former beauty queen, disappeared in October 2005 from her hometown of Ocilla. Her image was prominently displayed on billboards seeking information about her whereabouts until arrests were made in February 2017.

That was when Duke confessed to investigators that he had broken into Grinstead’s home to steal money for drugs. He reported to agents from the Georgia Bureau of Investigation that he was startled when Grinstead appeared behind him, leading him to strike and kill her.

Both Duke and Dukes informed investigators they had cremated Grinstead’s body after transporting it to the pecan grove in Ben Hill County. However, Duke later retracted his confession during his murder trial, instead accusing Dukes, claiming he had lied to police due to fear and intoxication. Dukes has never been charged with murder.

Two weeks following Duke’s trial in 2022, a grand jury in Ben Hill County indicted him on new charges related to Grinstead’s death, including an additional count of concealing a death, hindering the apprehension of a criminal, and tampering with evidence. Dukes still faced similar charges that had been filed in the same county back in 2017.

According to Georgia law, prosecutors had four years to file charges in the Ben Hill County case after establishing probable cause for arrest. The prosecution argued that this period started with the men’s confessions in February 2017. A lower court agreed with this assessment.

However, the Court of Appeals determined that the statute of limitations began in November 2005, approximately a month after Grinstead’s disappearance, when a man reported to the sheriff’s office that Duke and Dukes had allegedly confessed to him at a party about killing Grinstead and cremating her body.

“We conclude that law enforcement had probable cause to arrest the two men by late November 2005,” stated the court’s ruling.

Police claimed they did not have enough evidence to make arrests in late 2005, despite searching the pecan orchard based on the man’s tip and finding no trace of Grinstead.

Ultimately, the appeals court concluded that the four-year time limit had expired well before either man faced charges in Ben Hill County.

Duke is currently serving a 10-year sentence for concealing Grinstead’s death in Irwin County, while Dukes, who was also convicted for lying to police, received a 25-year prison sentence.

Grinstead’s remains have never been recovered. In 2017, Duke led investigators to the pecan grove in Ben Hill County where he claimed her body was burned. Although investigators found bone fragments that experts later confirmed were likely from an adult, DNA testing yielded inconclusive results.