Geiger v. State, 295 Ga. 190

Richard Geiger lived with Rosie Lee Smith; on March 6, 2007 he stabbed her during a confrontation after she told him to leave; she died at the scene.
Geiger admitted to a friend the same night that he had stabbed her and fled; an arrest warrant issued two days later.
Officers went to Geiger’s mother’s property in Bulloch County; as they approached they observed Geiger walking across a cotton field behind the house and arrested him without entering the house.
Geiger waived Miranda rights, confessed, led officers to the discarded knife; blood on the knife matched the victim.
At trial the jury convicted Geiger of felony murder (predicated on aggravated assault), aggravated assault, and felony possession of a knife; malice murder acquittal; he received life plus a consecutive five years for the weapon charge (concurrent 20-year sentence for aggravated assault later vacated as merged).
Geiger moved to suppress the arrest, seized evidence, and post-arrest statements as unlawful; he also sought mistrial for prosecutorial references to unproven prior incidents.

Issue	Geiger's Argument	State's Argument	Held
Validity of warrantless apprehension on mother’s property	Arrest was unlawful because officers entered curtilage without a search warrant; suppression required	Officers had an arrest warrant authorizing entry if Geiger lived there; alternatively Geiger was in an open field in plain view so no curtilage protection	Entry/arrest lawful or no standing; arrest and seizure upheld
Expectation of privacy in field behind house	Field was within curtilage; Fourth Amendment protection applies	Open fields doctrine precludes a reasonable expectation of privacy for field visible from road	No reasonable expectation of privacy; open-fields rule applies; arrest was permissible
Admissibility of confession and knife evidence	Statements and knife should be suppressed as fruits of illegal arrest	Confession voluntary after arrest; knife located per Geiger’s statement; evidence admissible	Confession and knife admissible; evidence supported conviction
Prosecutorial misconduct from referencing unproven prior incidents	Prosecutor injected impermissible, prejudicial matters; court failed to rebuke or give curative instruction thus requiring reversal or mistrial	Court admonished prosecutor outside jury; any error was harmless given overwhelming evidence	Court agreed prosecutor erred but held failure to rebuke/instruct harmless beyond a reasonable doubt; no reversible error

Jackson v. Virginia, 443 U.S. 307 (conviction must be supported by evidence from which a rational jury could find guilt beyond a reasonable doubt)
Minnesota v. Olson, 495 U.S. 91 (warrantless entry into a home where suspect resides implicates Fourth Amendment)
Payton v. New York, 445 U.S. 573 (arrest warrant implicitly authorizes entry into dwelling where suspect lives when reason to believe suspect is inside)
Steagald v. United States, 451 U.S. 204 (police generally need a search warrant to enter a third party’s home to execute an arrest warrant for a nonresident)
Oliver v. United States, 466 U.S. 170 (open fields are not protected by the Fourth Amendment)
California v. Ciraolo, 476 U.S. 207 (plain-view/observation doctrine limits expectation of privacy even within curtilage)
Miller v. State, 288 Ga. 286 (appellate standard for reviewing suppression-finding factual determinations)
O’Neal v. State, 288 Ga. 219 (trial court duty to rebuke prosecutor and give curative instructions for prejudicial statements)