Supreme Court of Georgia
State v. Abbott.
March 15, 2018812 S.E.2d 225
Summary
The court affirmed suppression of the defendant's pre-warning statements because the circumstances, including prolonged shackling in a closed interrogation room, established custodial interrogation before Miranda warnings. It vacated suppression of the post-warning statements and remanded because the lower court applied the wrong two-step-interrogation standard and did not determine whether the officer deliberately used the technique to undermine Miranda. The court clarified that the controlling inquiry requires consideration of deliberate police strategy and specified surrounding circumstances.