Summary
The Supreme Court of Georgia affirmed Don Robinson's convictions arising from a fatal shooting. The court held that statements Robinson made before receiving Miranda warnings while being treated at a hospital were admissible because he was not in custody when questioned. The court distinguished prior precedent involving more coercive hospital questioning and found no Miranda violation.
Holdings
- Robinson was not in custody when he made the statements about his arrival at the hospital because a reasonable person in his situation would not have perceived that he was formally arrested or restrained to the degree associated with a formal arrest.
Questions Presented
- Whether Robinson was in custody for Miranda purposes when he made pre-Miranda statements at the hospital about how he was injured and the vehicle in which he arrived.
- Whether the trial court erred in denying Robinson's motion to suppress those pre-Miranda statements.
Disposition
affirmed
Cases Cited (7)
- Jackson v. Virginia, 443 U.S. 307, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979)(followed)
- Reinhardt v. State, 263 Ga. 113, 428 S.E.2d 333 (1993)(distinguished)
- Tolliver v. State, 273 Ga. 785, 786, 546 S.E.2d 525 (2001)(followed)
- Miranda v. Arizona, 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966)(followed)
- Hardin v. State, 269 Ga. 1, 3, 494 S.E.2d 647 (1997)(followed)
- Hightower v. State, 272 Ga. 42, 43, 526 S.E.2d 836 (2000)(followed)
- Harris v. State, 273 Ga. 608, 543 S.E.2d 716 (2001)(followed)
Cited In (0)
No citing cases on record yet.
Court Document
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