Statev.Estrada
Tyler Estrada was in custody in DeKalb County when Gwinnett County investigators questioned him about a Gwinnett County homicide. During the recorded interview, Estrada said he did not want to discuss matters outside his DeKalb case without a lawyer and later again requested counsel. The investigator continued the conversation and Estrada made inculpating statements before the questioning stopped. The trial court suppressed the statement after finding that Estrada had invoked his right to counsel and had never waived his Miranda rights. The Supreme Court of Georgia affirmed. Reviewing the evidence in the light most favorable to the trial court’s factual findings, the Court held that the record supported the finding that Estrada’s request for counsel was clear and that the State had not shown a valid waiver before the statements were obtained. The court deferred to the trial court’s credibility findings and the recording’s undisputed contents. The suppression order remained in effect, and all the Justices concurred.
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