FITZGERALD, Ga. – The Georgia Court of Appeals has dismissed pending criminal charges against two men previously convicted of concealing the death of high school teacher Tara Grinstead, whose 2005 disappearance left investigators and her family searching for answers for over a decade.
The court ruled Thursday that the statute of limitations had expired before prosecutors in Ben Hill County charged Ryan Duke and Bo Dukes with crimes related to the burning of Grinstead’s body in a remote pecan orchard nearly two decades ago.
Despite this decision, prior convictions remain unaffected. In 2022, Duke was convicted in Irwin County, where Grinstead lived, for concealing her death, though a jury acquitted him of murder. Meanwhile, Bo Dukes was convicted in 2019 for covering up the crime. Both men are currently serving prison sentences.
A Decade-Long Mystery Finally Sees Arrests
Grinstead, a 30-year-old high school teacher and former beauty queen, disappeared from her home in Ocilla, Georgia, in October 2005. Her face became widely recognized due to billboards and media campaigns that sought information on her whereabouts. It wasn’t until February 2017 that arrests were finally made.
At that time, Ryan Duke confessed to breaking into Grinstead’s home to steal money for drugs. According to his statement to the Georgia Bureau of Investigation (GBI), he panicked when Grinstead confronted him and struck and killed her.
Both Duke and Bo Dukes told investigators that they burned Grinstead’s body in a pecan grove in Ben Hill County to destroy evidence. However, during his 2022 murder trial, Duke recanted his confession, claiming he had lied out of fear and intoxication. Instead, he accused Bo Dukes of killing Grinstead.
Bo Dukes, however, was never charged with murder.
Court Dismisses New Charges, Citing Expired Statute of Limitations
In 2022, just two weeks after Duke’s murder trial, a Ben Hill County grand jury indicted him on additional charges tied to Grinstead’s death. These included:
- Concealing a death
- Hindering the apprehension of a criminal
- Evidence tampering
Bo Dukes also still faced similar charges in Ben Hill County dating back to 2017.
However, under Georgia law, prosecutors had a four-year window to file these charges once they had probable cause. Prosecutors argued that the statute of limitations began with Duke and Dukes’ 2017 confessions.
A lower court initially agreed with them.
The Georgia Court of Appeals, however, ruled that the statute of limitations had already expired long before those charges were filed. The court determined that law enforcement had probable cause to arrest Duke and Dukes as early as November 2005, after a man reported that the pair had confessed at a party to killing Grinstead and burning her body.
“We conclude that law enforcement had probable cause to arrest the two men by late November 2005,” the court’s ruling stated.
Authorities at the time searched the pecan grove based on the tip but found no evidence, leading them to delay arrests for over a decade.

Grinstead’s Body Remains Missing
Despite extensive searches, Grinstead’s remains were never fully recovered. In 2017, Duke led investigators to the pecan grove in Ben Hill County, where he claimed her body had been burned.
Investigators recovered bone fragments, and forensic experts testified that they were consistent with an adult human. However, DNA analysis was inconclusive, leaving her family without definitive closure.
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What Happens Next?
Although the pending charges against Duke and Dukes have been dismissed, their existing convictions remain in place:
- Ryan Duke is serving a 10-year sentence for concealing Grinstead’s death in Irwin County.
- Bo Dukes, convicted of lying to police, is serving 25 years in prison.
This ruling marks another twist in a case that has haunted Georgia for nearly 20 years, leaving lingering questions about justice and whether all responsible parties have been held accountable.