After a car hijacking and attempted armed robbery, police questioned Darievq Richardson at his apartment and later arrested him. The trial court suppressed statements Richardson made before and after his arrest and suppressed a gun recovered from the apartment. The State appealed. The Georgia Court of Appeals held that Richardson’s initial conversation with police was not custodial and was voluntary, even though officers had not yet given Miranda warnings. The court emphasized that the brief encounter occurred before arrest, Richardson was not restrained, and the trial court found that the officers’ omission was inadvertent rather than a deliberate question-first, warn-later strategy. The court therefore reversed the suppression of the pre-arrest statements and the gun, which the trial court had treated as derivative evidence. Because the parties and trial court had not adequately addressed the statements made after arrest, the appellate court vacated that portion of the order and remanded for further proceedings.