Oubre v. WoldemichaelAnnotate this Case
Yididya Woldemichael pleaded guilty to armed robbery and other charges for his role in the robbery and beating of a pizza delivery woman. He filed a petition for habeas corpus, which was granted on grounds that his trial counsel was ineffective for failing to advise Woldemichael that inculpatory custodial statements could have been suppressed. Woldemichael was 14 years old at the time of the police interview. The Warden appealed the grant of habeas relief, arguing that the statements were voluntary and would have been admissible at trial and, thus, counsel’s performance was not deficient. The Georgia Supreme Court agreed with the habeas court that Woldemichael’s statements to police were subject to suppression. But because the habeas court assumed, without separate analysis, that recorded statements that Woldemichael made to a co-defendant during a break in police questioning also were subject to suppression, it remanded for the habeas court to analyze the admissibility of those statements in the first instance.