Causey v. State, 307 Ga. 147

Victim Lydia Ivanditti was found dead in her bathtub on Dec. 2, 2016; cause of death was manual strangulation and drowning with bruising to neck and forehead.
Items at the scene included a broken cell phone and phone parts with Causey’s blood/DNA and towels with Causey’s DNA; police believed some items had been arranged to simulate an accident.
Phone records and surveillance placed Causey’s calls to Ivanditti the night she died and showed a vehicle linked to Causey at or leaving from her residence; a neighbor saw a person leave the house and go to a maroon SUV owned by Causey.
Causey made statements to police (including “I did it” and admissions that he choked Ivanditti for 15–20 seconds) after two custodial interviews; the State also introduced prior-act evidence that Causey had choked prior partners and disabled their phones.
Trial: convicted of malice murder and sentenced to life without parole; Causey appealed arguing insufficiency of evidence and improper admission of custodial statements and other evidence. Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict	State: circumstantial and forensic evidence plus admissions place Causey as the killer	Causey: no evidence definitively placing him at Ivanditti’s home at time of death	Guilty verdict affirmed; evidence sufficient under Jackson v. Virginia
Admissibility of custodial statements after alleged invocation of right to silence	State: Causey never clearly and unambiguously invoked silence; he re‑initiated and made spontaneous admissions	Causey: he invoked his Miranda right to remain silent and subsequent statements should be suppressed	Court: no clear invocation; statements admissible (re‑initiation and spontaneous utterances valid)
Admission of OCGA §24‑4‑404(b) prior‑act evidence	State: evidence of prior choking incidents shows intent, motive, or pattern	Causey: prior acts were unduly prejudicial and inadmissible	Court allowed 404(b) evidence; it was probative and considered in assessing guilt

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
Berghuis v. Thompkins, 560 U.S. 370 (suspect must clearly and unambiguously invoke right to remain silent)
Jackson v. Denno, 378 U.S. 368 (pretrial hearing to determine voluntariness/admissibility of confessions)
Miranda v. Arizona, 384 U.S. 436 (requirement to advise custodial suspects of rights)
Perez v. State, 283 Ga. 196 (Georgia: authorities must scrupulously honor clear invocation of silence)
Ridley v. State, 290 Ga. 798 (officer not required to clarify equivocal invocation)
Brown v. State, 304 Ga. 435 (discussion of equivocation standard for invoking right to silence)
Cook v. State, 274 Ga. 891 (continuing to talk after saying one does not want to talk renders request equivocal)
Johnson v. State, 301 Ga. 707 (statements from conversations a defendant initiates and spontaneous utterances can be admissible)