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State v. Estrada

The trial court did not err in suppressing defendant's custodial statement, because law enforcement officers violated his constitutional rights when they did not cease interrogating him after he twice unequivocally invoked his right to counsel; further, defendant never retracted his unequivocal request for a lawyer and he never initiated additional conversation with officers after they left the interrogation room.

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On November 7, 2013, appellee Tyler Estrada, who was 18 years old at the time, was in custody in DeKalb County when two Gwinnett County police investigators questioned him about a Gwinnett County homicide.1 Upon holding an evidentiary hearing at which the lead interrogating officer testified and at which audio recordings of appellee’s custodial statement were placed into evidence, the trial court determined appellee had invoked his right to counsel and never waived his Miranda2 rights either in writing or verbally. Accordingly, it granted appellee’s motion to suppress the statement and the State now appeals. We affirm.

When reviewing a trial court’s ruling on a motion to suppress, an appellate court must construe the evidentiary record in the light most favorable to the factual findings and judgment of the trial court. This means that the reviewing court generally must accept the trial court’s findings as to disputed facts unless they are clearly erroneous, although the reviewing court may also consider facts that definitively can be ascertained exclusively by reference to evidence that is uncontradicted and presents no questions of credibility such as facts indisputably discernible from an audio recording.

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