Jairus Collins v. State of Mississippi, 172 So. 3d 724

Victim Ebony Jenkins was found shot to death in Hattiesburg on Dec. 9, 2011; Jairus Collins was identified as a suspect and later indicted for murder and weapons possession as a habitual offender.
Collins moved to suppress his custodial statement, arguing officers continued interrogation after he invoked his right to counsel.
Video/transcript shows Collins asked for a lawyer, officers left the room, Collins reinitiated contact with an officer, and detectives then continued questioning without giving a new Miranda warning.
Detective Joey Scott actively questioned Collins after recontact; Collins again asked for counsel during the interview but questioning persisted.
Detective Casey Sims, who had taken a 16‑hour course in cellular technology, testified without being qualified as an expert about cell‑tower records and presented maps purporting to locate Collins and Jenkins at relevant times.
The trial court denied suppression and allowed Sims to give opinion-style testimony as a lay witness; Collins was convicted and sentenced to life; the Mississippi Supreme Court granted certiorari and reversed and remanded on suppression and expert‑testimony grounds.

Issue	Collins' Argument	State's Argument	Held
Whether custodial statements after Collins invoked right to counsel should have been suppressed	Officers continued interrogation after he requested a lawyer; his recontact was only to ask routine custodial questions and he did not validly initiate interrogation; any later waiver was not knowing and intelligent	Collins reinitiated contact after officers left the room; therefore Edwards/Bradshaw allow further questioning and the subsequent statements were admissible	Reversed: trial court applied wrong standard. Collins did not "initiate" interrogation under Edwards/Bradshaw; even if he had, prosecution failed to prove a valid waiver beyond reasonable doubt
Whether testimony locating phones from historical cell‑site data may be offered by a lay witness or requires expert qualification	Sims’ mapping and location opinions required specialized technical knowledge and he should have been qualified and disclosed as an expert	The State treated the testimony as lay explanation of phone records and mapping	Reversed as to Sims’ testimony: basic record description is lay, but drawing inferences pinpointing users’ locations from cell‑site/antenna data requires expert testimony and disclosure; admitting Sims’ opinion without qualification was error

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial‑interrogation warnings and right to counsel)
Edwards v. Arizona, 451 U.S. 477 (1981) (once right to counsel invoked, police‑initiated interrogation must cease unless accused initiates further communication)
Oregon v. Bradshaw, 462 U.S. 1039 (1983) (distinguishing initiation of conversation from valid waiver analysis)
Haynes v. State, 934 So. 2d 983 (Miss. 2006) (Mississippi standards on initiation and waiver under Edwards/Bradshaw)
Heflin v. Merrill, 154 So. 3d 857 (Miss. 2014) (Rule 701 prohibits lay opinions based on specialized training)
Kirk v. State, 160 So. 3d 685 (Miss. 2015) (police testimony that crossed into expert medical opinion required expert qualification)
Wilder v. State, 991 A.2d 172 (Md. Ct. Spec. App. 2010) (cell‑site mapping and plotting testimony requires expert testimony)
Patton v. State, 419 S.W.3d 125 (Mo. Ct. App. 2013) (historical cell‑site data location inferences are expert opinions)
United States v. Evans, 892 F. Supp. 2d 949 (N.D. Ill. 2012) (distinguishing lay testimony about call records from expert testimony on cellular network operation and granulization)