Miller v. State
288 Ga. 286
| Ga. | 2010Background
- July 30, 2008, TRAP unit officers observed a group near a vacant car; car lacked a license plate and windows were tinted.
- Miller was among the group and moved away toward his mother’s home; Officer Williams pursued and wrestled Miller to the ground.
- A gun protruded from Miller’s pocket after the takedown; a pat-down revealed cocaine in Miller’s pants pocket.
- Trial court credited inconsistencies in Williams’ stop rationale and found no objective basis for the stop; suppression granted.
- Court of Appeals reversed the suppression ruling, applying de novo review; Supreme Court granted certiorari to review the standard of review.
- Supreme Court reversed the Court of Appeals, holding that the trial court’s credibility determinations and rationale should be reviewed under a clearly erroneous standard; judgment to suppress was affirmed on the contrary reasoning.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review for suppression orders | Miller: de novo is proper for appellate review | State: de novo review warranted | De novo standard improper; clearly erroneous standard applies |
| Whether the stop was based on reasonable suspicion | Group observations and tinting suggested suspicious activity | No objective basis; stop was a mere hunch | Stop supported by totality of circumstances; reasonable suspicion established under Terry/Arvizu |
| Credibility and reliance on trial-court findings | Trial court credibility supports suppression | Appellate court may reweigh credibility | Trial court findings control; credibility assessed at the trial level must be given deference |
| Collective knowledge of officers in minor stop | Knowledge of all officers should be considered | Only Williams’ knowledge matters | Knowledge of the entire team can be imputed; stop lawful based on collective observations |
Key Cases Cited
- Tate v. State, 264 Ga. 53 (1994) (framework for appellate review of suppression motions; trier of fact rules; credibility principles)
- Whren v. United States, 517 U.S. 806 (1996) (Terry stop based on objective criteria, not subjective motive)
- State v. Miller, 300 Ga. App. 55 (2009) (Court of Appeals de novo review questioned; context for suppression rulings)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality of the circumstances; particularized and objective basis for stop)
- Silva v. State, 278 Ga. 506 (2004) (appellate review of suppression; credibility and findings; collective knowledge considerations)
- Drake v. County of Essex, 275 N.J. Super. 585 (1994) (group behavior and tinting as indicators of possible wrongdoing)
- Brooks v. State, 206 Ga. App. 485 (1992) (collective knowledge in investigative stops)
- Burgess v. State, 290 Ga. App. 24 (2008) (collective actions in stops; disclosure and timing of stops)