Dequavius Franklin was charged with murder and related offenses after making a statement to law enforcement while hospitalized. The trial court suppressed the statement, finding that medication, medical conditions, and the surrounding circumstances made it involuntary. The State appealed. The Supreme Court of Georgia reversed, holding that the record contained no evidence of coercive police conduct sufficient to support suppression on voluntariness grounds. The Court explained that the voluntariness inquiry focuses on coercion by law enforcement and that the trial court had applied the wrong legal standard to the undisputed circumstances. A separate writing agreed with the result but cautioned that a broader examination of the treatment of recorded statements and related issues should await an appropriate case.