Georgia v. ClarkAnnotate this Case
The State appealed the trial court’s pre-trial decision to suppress statements made by appellee William Clark during a police station interview. In 2008, appellee called 911 after assaulting and killing his paramour, Deborah Jeffries, by striking her in the head with a golf club and stabbing her in the chest more than twenty times. Detective J.D. Stephens of the Atlanta Police Department testified he began video-recording the interview after appellee had already been talking for seven minutes. The video recording was approximately 33 minutes long. Less than 30 seconds into the recording, appellee says, “This is off the record,” and Detective Stephens responds, “Yeah.” Appellee then proceeds to discuss his three-year history with the victim, accusing her of various nefarious activities and describing how she used her relationships with other men to goad him into becoming upset or angry. About 22 minutes into the recording, Detective Stephens reminds appellee that he was read his rights. Appellee simply continues to talk. At approximately 28 minutes into the interview, appellee puts his head down on the table, but keeps talking. Appellee eventually describes the point at which he hit and stabbed the victim. Detective Stephens again reminded appellee that his rights were read to him. While Detective Stephens is out of the room, appellee can be seen on the video climbing on top of the table, then lying down on it as if in distress. The video then stops. According to Detective Stephens, the paramedics found nothing wrong with appellee and, after they left, he resumed interviewing appellee for about 40 more minutes, but did not record it. At the trial court’s hearing on appellee’s suppression motion, the trial court stated it believed Detective Stephens had read appellee his Miranda rights, but it did not believe appellee understood those rights. The trial court granted appellee’s motion to suppress his videotaped custodial statement on the ground the State failed to carry its burden to show it was voluntary. The Supreme Court affirmed.