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The Statev.Rumph

CourtSupreme Court of Georgia
Docket No.S19A0995
DecidedDecember 23, 2019
Reporter307 Ga. 477
JudgesSupreme Court of Georgia
Tags
CriminalCriminal LawCriminal ProcedureEvidenceConstitutional LawDue ProcessReversal
Case Summary

Christopher Rumph gave investigators two recorded statements before his arrest for murder and related offenses. The first occurred at his home after investigators asked to speak with him, and the second occurred at a sheriff’s-office substation where he was allowed to keep his phone and keys, take breaks, receive calls, and leave after the interview. Rumph later asked for a lawyer, and officers stopped questioning him. The trial court suppressed the first two statements because investigators had not given Miranda warnings. The Georgia Supreme Court reversed. It held that Miranda warnings are required only during custodial interrogation, and the recorded circumstances did not show a formal arrest or that a reasonable person would have believed he was in custody. Rumph voluntarily agreed to the conversations, was not restrained, and was told he was not being charged at the time. The Court therefore held that the statements were admissible and reversed the suppression order. All justices concurred.

Opinion

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