Crawford v. State, 288 Ga. 425

Roy Crawford was convicted of murder in the drowning death of Seliqueka Curry and challenged the denial of his motion for new trial.
Evidence showed Crawford was outside the victim's apartment the morning of the murder; the victim was found dead in the bathtub that afternoon, with a damaged back door.
A blood stain matching the victim was found on Crawford’s pants after his arrest; medical testimony linked death to drowning with head injuries and strangulation.
Crawford initially denied being in the victim's apartment, later admitted being there, and disputed the questioning context.
The defense sought suppression of Crawford’s police statement; the record relied in part on Jackson-Denno proceedings and two recorded DVDs not transcribed in the appellate record.
The trial court denied suppression and instructed the jury on the charges; Crawford also challenged absence of certain jury instructions, including Miranda and accident, and the voluntary manslaughter charge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Custody determination for suppression	Crawford was in custody; suppression should have been granted.	Not in custody; interrogation was voluntary.	No error; not in custody under objective circumstances.
Miranda waiver and voluntariness despite unsigned form	Miranda waiver not voluntary because form not signed.	Unsigned waiver does not automatically render statements involuntary.	Not involuntary; unsigned waiver not fatal to admissibility.
Request for counsel during interrogation	Appellant asked if he needed an attorney, triggering right to counsel.	Question did not constitute an unambiguous request for counsel.	No obligation to stop questioning; no unequivocal request for counsel.
Failure to instruct on accident and allowance of voluntary manslaughter	Charge on voluntary manslaughter should have been given based on evidence	Evidence did not show serious provocation or romance with victim; no basis for manslaughter instruction.	Refusal to give voluntary manslaughter charge affirmed; no evidence of sufficient provocation.

Hardin v. State, 269 Ga. 1 (1998) (custody determined by objective circumstances; not subjective)
Sewell v. State, 283 Ga. 558 (2008) (clear error standard for custody determinations)
Byrd v. State, 261 Ga. 202 (1991) (equivocal vs. unequivocal request for counsel standard)
Moon v. State, 253 Ga. 74 (1984) (waiver of rights and requested instructions procedures)
Goforth v. State, 271 Ga. 700 (1999) (provocation in voluntary manslaughter; romance requirement absence)
Jackson v. Virginia, 443 U.S. 307 (1981) (sufficiency standard for murder verdicts)