Daniels v. State, S21A1268

Background

Defendant Kevonta Daniels (age 14 at arrest) was convicted of felony murder and related offenses after a home burglary and subsequent shooting; he received life plus additional prison terms and appealed denial of his motion for new trial.
Daniels was arrested January 11, 2018, and subjected to multiple recorded custodial interviews over the day (about 5–6 hours total); juvenile-specific Miranda/advice-of-rights forms were read and signed twice.
Interrogating officers questioned Daniels about numerous vehicle thefts and the Curry Street burglary/shooting; portions of audio were garbled and parts of recordings were redacted at trial.
Daniels argued his custodial statements should have been excluded because (1) police violated OCGA §15-11-502 by not promptly presenting him to juvenile court and (2) he did not knowingly and voluntarily waive Miranda rights under the Riley juvenile-waiver factors.
Trial court held two Jackson–Denno hearings, admitted the statements, and denied the amended motion for new trial; the Georgia Supreme Court affirmed admission of the statements.

Issues

Issue	Plaintiff's Argument (Daniels)	Defendant's Argument (State)	Held
Compliance with Juvenile Code (OCGA §15-11-502)	Officers detained Daniels for interrogation and did not immediately bring him before juvenile court; statements should be excluded.	Subsection (b) authorizes reasonable detention for interrogations and routine procedures; 5–6 hours was reasonable given multiple matters to investigate.	Court: No plain, clear error; detention fell within subsection (b) exception. Statements not excluded on this basis.
Knowing & voluntary Miranda waiver (Riley factors)	Daniels (juvenile, borderline/low-average functioning per later evaluation) did not validly waive rights given age, multiple interrogators, length, emotional distress, and alleged promises.	Daniels was twice advised on juvenile rights, signed waiver forms, never requested counsel or parent presence during interviews, was given breaks/food, and was not coerced.	Court: Under the Riley totality test, waiver was knowing and voluntary; trial court’s factual findings not clearly erroneous.
Need for explicit, factor-by-factor findings on Riley	Trial court failed to announce specific findings for each Riley factor on the record; thus ruling was deficient.	Trial court considered Riley factors during Jackson–Denno hearings; explicit on-the-record recitation of each factor is not required.	Court: No requirement to make separate explicit findings for each Riley factor; record shows factors were considered and supports admission.

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishing Miranda warnings and waiver framework)
Jackson v. Denno, 378 U.S. 368 (U.S. 1964) (hearing requirement for voluntariness of confessions)
Riley v. State, 237 Ga. 124 (Ga. 1976) (nine-factor test for juvenile Miranda waivers)
Bedford v. State, 311 Ga. 329 (Ga. 2021) (State’s burden to prove juvenile waiver by preponderance; Riley factors applied)
Lester v. State, 310 Ga. 81 (Ga. 2020) (appellate review of trial court’s waiver findings and Riley application)
Oubre v. Woldemichael, 301 Ga. 299 (Ga. 2017) (consideration of interrogation length and hope-of-benefit in voluntariness analysis)
Love v. State, 309 Ga. 833 (Ga. 2020) (juvenile’s ability to read/understand is relevant to waiver)
Gates v. State, 298 Ga. 324 (Ga. 2016) (plain-error standard for admission of evidence on appeal)
Dawson v. State, 308 Ga. 613 (Ga. 2020) (courts may rely on undisputed facts in recordings when reviewing waiver/voluntariness)
Chapman v. State, 273 Ga. 865 (Ga. 2001) (interrogation abusive/coercive standards)
State v. Lee, 298 Ga. 388 (Ga. 2016) (example where juvenile waiver found invalid under totality of circumstances)
Chulpayev v. State, 296 Ga. 764 (Ga. 2015) (distinguishing statutory voluntariness under OCGA §24-8-824 from constitutional due-process analysis)
Matthews v. State, 311 Ga. 531 (Ga. 2021) (contrast of statutory and constitutional voluntariness standards)
Budhani v. State, 306 Ga. 315 (Ga. 2019) (harmless-error review for erroneous admission of confession)
Arizona v. Fulminante, 499 U.S. 279 (U.S. 1991) (federal due-process voluntariness precedents)
United States v. Lall, 607 F.3d 1277 (11th Cir. 2010) (rejecting per se rule that any promise, however slight, renders confession involuntary)
Murphy v. State, 267 Ga. 100 (Ga. 1996) (trial court’s credibility determinations on promises and coercion are entitled to deference)
Dixon v. State, 302 Ga. 691 (Ga. 2017) (procedural note on merger issues)