State v. Brown, 287 Ga. 473

Summary

The Supreme Court of Georgia held that Roger Brown unequivocally invoked his Miranda right to counsel, but that the police did not thereafter subject him to interrogation or its functional equivalent. Because Brown's subsequent statements were volunteered and not coerced, the court reversed the trial court's order suppressing those statements.

Holdings

1. Brown unequivocally invoked his right to counsel when he stated, "I want a lawyer," and repeated that statement after the detective confirmed his request.
2. A request for counsel does not automatically require suppression of every subsequent statement; the court must determine whether police engaged in further interrogation and, if so, whether the defendant initiated the additional communication.
3. The detectives did not subject Brown to further interrogation or its functional equivalent after he invoked his right to counsel, and Brown's unsolicited post-invocation admissions were admissible.

Questions Presented

1. Whether Brown unequivocally invoked his Miranda right to counsel.
2. Whether statements Brown made after invoking his right to counsel were obtained through further police interrogation or its functional equivalent.
3. Whether the detectives' continued presence, responses to Brown's questions, and efforts to contact counsel required suppression of Brown's post-invocation statements.

Disposition

reversed