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Ramsey v. State

Since defendant's statements to the police officer who arrived at the crime scene were spontaneous, they were admissible even though he did not receive Miranda warnings.

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Appellant James Ramsey was convicted of the 1995 murder of his wife, Mauricette Jacqueline Ramsey.1 On December 3, 1995, appellant shot and killed his wife at the apartment complex where he lived with the victim and their son. Appellant had just returned from a nightclub, where he had been drinking. Upon his arrival, appellant got into an argument with the victim. During the argument, the victim informed appellant that she had been unfaithful and that he might not be the father of their son. Appellant then went into his son’s room to obtain his gun. Soon thereafter, appellant shot the victim.

Officer Gravitt, the first police officer on the scene, testified that upon arriving at appellant’s residence, he was directed to a bedroom where the victim lay. Afterward, while the officer waited in the living room with appellant, he told the officer that he had come home at about 4:30 a.m. and that the victim had confronted him about where he had been that night. Appellant stated that he then went into his son’s bedroom to obtain his gun in order to clean it. According to appellant, as he dropped the clip out of the gun, the gun fired and hit the victim in the head. After being read his Miranda rights, appellant gave a similar statement at an interview at the police station.

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