Benton v. State, 302 Ga. 570

On July 17, 2008, multiple people were shot outside an apartment complex; Christopher Ramsay was killed and others wounded. An eyewitness later identified Benton as one of the shooters.
Benton was indicted and convicted by a Fulton County jury of malice murder and related offenses; he was sentenced to life plus additional terms. He moved for a new trial, which was denied; he appealed.
Benton was arrested September 9, 2008, and interviewed on video by police. He denied killing Ramsay but admitted prior shootings at Ramsay and discussed a dispute about a four-wheeler.
At a Jackson–Denno hearing the trial court found Benton had been read Miranda warnings, understood and waived them, and admitted the videotaped interview at trial.
On appeal the Georgia Supreme Court reviewed the recorded interview de novo and concluded Benton did not knowingly and intelligently waive Miranda rights because he did not understand the warnings as read and the officer’s follow-up explanation omitted three critical warnings.
The Court reversed the convictions and ordered a new trial because the custodial statements were obtained in violation of Miranda and the State did not contend the error was harmless.

Issue	Plaintiff's Argument (Benton)	Defendant's Argument (State)	Held
Whether custodial statements should be suppressed for lack of a valid Miranda waiver	Benton argued he did not understand the Miranda warnings as read and therefore did not knowingly and intelligently waive rights	State relied on the officer’s reading of the warnings, Benton’s nods and subsequent colloquy to show waiver	Reversed: waiver invalid — Benton did not understand warnings; officer’s simplified explanation omitted that statements could be used in court, right to counsel, and appointment of counsel if indigent
Whether the trial court’s factual finding based on the videotape is entitled to deference	Benton argued the tape shows he lacked comprehension; appellate review of videotape is de novo	State argued trial court credibility finding should stand	Court applied de novo review to videotaped exchange and agreed Benton lacked comprehension
Whether any Miranda error was harmless	Benton argued error was not harmless because his statements materially supported State’s case	State did not assert harmless-error at oral argument or in briefing	Court found error not harmless given reliance on eyewitness plus Benton’s statements and reversed
Whether other trial errors require review now	Benton raised additional evidentiary and prosecutorial-error claims	State would argue those are preserved for retrial or without merit	Court declined to address remaining claims as moot or unlikely to recur on retrial

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required for custodial interrogation)
Jackson v. Virginia, 443 U.S. 307 (sufficiency of the evidence review standard)
Jackson v. Denno, 378 U.S. 368 (pretrial hearing on voluntariness of confessions)
Berghuis v. Thompkins, 560 U.S. 370 (waiver must be knowing and intelligent)
Duckworth v. Eagan, 492 U.S. 195 (Miranda warnings need not be verbatim but must be adequate)
United States v. Street, 472 F.3d 1298 (11th Cir.) (incomplete Miranda warning defective when it omits key advisals)
Clay v. State, 290 Ga. 822 (Georgia standard on Miranda waiver and intelligibility)
Bunnell v. State, 292 Ga. 253 (totality-of-the-circumstances review for voluntariness)