Georgia v. Troutman
Annotate this CaseDuring the course of investigating the murder of Earl Clemons, investigators learned through a witness and cellular telephone records that appellant Andrew Troutman may have met with Clemons on the day of the murder. In this pre-trial appeal, the State challenged the trial court’s order suppressing Troutman’s inculpatory statement. The trial court determined that Troutman was in custody prior to the beginning of a third interview and that, because investigators never advised Troutman of his Miranda rights, Troutman’s subsequent inculpatory statement was inadmissible. On appeal, the State contended that Miranda warnings were unnecessary because Troutman was not in custody. The Supreme Court found that under the circumstances of this case, in which Troutman was sequestered for hours, repeatedly interviewed, and never given any indication that he was free to leave or terminate the interview (and advised the he could not go), the Supreme Court could not say that the trial court erred in its determination that a reasonable person in Troutman’s position would have believed that he was in custody before the start of the third interview and, thus, that Troutman’s unwarned statement given during that third interview was due to be suppressed. With respect to the issue of whether the in-custody statement admitted in violation of Miranda was, nevertheless, voluntary under traditional due process standards, the trial court concluded that Troutman’s statement to investigators was involuntary and, thus, could not be used at trial for any purpose. On appeal, the States contended that these facts were insufficient to conclude that Troutman’s statement was involuntary. With that contention, the Supreme Court agreed. The Court therefore affirmed in part, reversed in part, and remanded for further proceedings.
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