The State appealed suppression of three statements 16-year-old Jalen McGriff made to investigators after his infant daughter died. The Supreme Court of Georgia held that the trial court had given too much weight to his age and had not made enough findings about whether a reasonable person in his circumstances would have felt unable to leave the first two interviews. It vacated those rulings for further findings rather than deciding custody from the incomplete record. For the final, recorded interview, the court concluded that McGriff knowingly and voluntarily waived his Miranda rights under the totality of the circumstances, despite his youth, and reversed suppression of that statement. The decision separates the question whether an interview was custodial from whether a warned suspect validly waived the right to remain silent.