Fifteen-year-old Paris Powell made several statements to police during interviews about a fatal shooting. Her mother was present, and the trial court found that Powell was not in custody during the interviews but suppressed part of the final statement after concluding that it was not voluntarily made under constitutional due process principles. The State appealed. The Supreme Court of Georgia affirmed the suppression ruling. The Court declined to decide whether Powell clearly invoked the right to remain silent and instead held that the State failed to carry its burden of proving a knowing and voluntary waiver under the totality of the circumstances. The majority relied on the trial court’s factual and credibility findings. A separate opinion argued that the Court should clarify the standard governing juvenile statements obtained in noncustodial settings and reconsider the controlling analysis in a future case.