Boyd v. State, 315 Ga. App. 256

Boyd, 15 years old, was identified by a victim as the person with the sawed-off shotgun during a robbery.
He was interviewed in custody around 2:20 a.m. after being arrested hours after the crime.
Miranda rights were read in a first-person form; Boyd nodded assent and said he understood.
The officer pressed Boyd to ‘straighten out what happened,’ and Boyd ultimately admitted he did it, claiming the gun was unloaded.
The trial court admitted the in-custody statement; the show-up identification of Boyd by the victim was also admitted.
The Georgia Court of Appeals reversed on the in-custody statement issue but affirmed the show-up identification ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Boyd validly waived his rights for the custodial statement	Boyd’s waiver was knowing and voluntary under Riley factors.	Waiver was not knowing/voluntary given youth and circumstances.	Statement excluded; waiver not knowing/voluntary.
Whether the show-up identification was properly admitted	Identification should be admissible despite some telltale factors.	Show-up was improper/unduly suggestive.	Show-up identification admissible; no reversible error.

J.D.B. v. North Carolina, 131 S. Ct. 2394 (2011) (U.S. Supreme Court 2011) (age is a factor in juvenile custodial interrogations)
Riley v. State, 237 Ga. 124, 226 S.E.2d 922 (1976) (Georgia Supreme Court 1976) (nine Riley factors for juvenile waiver)
Vergara v. State, 283 Ga. 175, 657 S.E.2d 863 (2008) (Georgia Supreme Court 2008) (video/interview context in suppression determinations)
State v. Brown, 308 Ga. App. 480, 708 S.E.2d 63 (2011) (Georgia Court of Appeals 2011) (videotaped interrogation considerations)
Swain v. State, 285 Ga. App. 550, 647 S.E.2d 88 (2007) (Georgia Court of Appeals 2007) (juvenile interrogation methods and voluntariness)
In the Interest of C.H., 306 Ga. App. 834, 703 S.E.2d 407 (2010) (Georgia Court of Appeals 2010) (eighth-grade education sufficiency for Miranda waiver)