Mackv.State
Artenimus Mack was questioned after his arrest for a 2012 shooting. During the first interview, after investigators challenged his account and urged him to tell the truth, Mack repeatedly said that he was done talking and wanted to return to jail. The questioning continued, and Lieutenant Langford later urged Mack to tell the truth again before ending the interview. Langford resumed questioning Mack the next morning, and a second interview followed after Mack asked to speak with him; Mack confessed during that later interview. The trial court denied suppression, concluding that Mack had not clearly asked questioning to stop and that he had later initiated renewed contact with police. The Supreme Court of Georgia reversed. It held that Mack’s repeated statements that he had no more to say were an unambiguous invocation requiring questioning to stop. Because officers did not scrupulously honor that invocation, a later statement was admissible only if Mack independently initiated renewed communication and the contact was not the product of the earlier unlawful interrogation. The court held that Langford initiated the first interview the next morning and that Mack’s request for the later interview resulted from the improper questioning, so the court ordered suppression of all statements after the invocation and expressly adopted that causation-focused initiation rule.
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