Reid v. State
306 Ga. 769
Ga.2019Background
- On May 22, 2013, three‑year‑old Jakarie Reid was admitted to hospital with multiple recent blunt‑force injuries (including subdural hematoma, retinal hemorrhages, abdominal lacerations) and later died; autopsy ruled cause of death blunt force head trauma.
- Neighbors and a housemate (Latonya Sanders) heard Reid yelling and a child being struck earlier the same morning; Sanders found Jakarie unconscious in Reid’s arms and performed CPR before EMS arrived.
- Reid gave multiple recorded statements to DFCS investigator William Herndon (once at the hospital and once at the police detective bureau) admitting discipline but giving inconsistent accounts of how injuries occurred; no law‑enforcement officers were present for those DFCS interviews.
- While jailed pretrial, Reid made recorded phone calls to her mother in which she discussed a trial strategy to blame Sanders; the recordings were played to the jury.
- Reid was convicted by a jury of malice murder and cruelty to children (malice murder life without parole); she appealed, arguing insufficient evidence and that the trial court erred in admitting (a) the detective‑bureau/DFCS interview (Miranda, Jackson‑Denno, Sixth Amendment issues) and (b) the jail call (attorney‑client privilege, notice, authentication).
Issues
| Issue | Reid's Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for convictions | Evidence was insufficient to prove Reid caused Jakarie’s fatal injuries | Physical injuries, patterns consistent with household objects, expert testimony, witnesses hearing beating supported conviction | Affirmed — evidence sufficient under Jackson v. Virginia standard |
| Admissibility of DFCS detective‑bureau recording (Miranda / custodial interrogation) | Interview was custodial; no Miranda warnings given; statements after invocation should be excluded | DFCS investigator was not law enforcement; Reid was not in custody; Miranda not required; warnings were later given by a detective | Affirmed — not custodial; Miranda not required; warnings given later before any custodial interrogation |
| Voluntariness / Jackson‑Denno hearing for DFCS statement (Due Process) | Court should have held Jackson‑Denno hearing and excluded statements as involuntary | Reid objected only under Miranda; no contemporaneous voluntariness claim or request for Jackson‑Denno hearing | Affirmed — no contemporaneous voluntariness objection so no sua sponte Jackson‑Denno required |
| Sixth Amendment (Massiah/Brewer) challenge to DFCS interview | Statements elicited after proceedings began; deliberate elicitation by government violated right to counsel | No judicial proceedings had begun when DFCS interview occurred; Sixth Amendment not yet attached | Affirmed — Sixth Amendment not implicated because no judicial proceedings had been initiated |
| Admissibility of jail call recording (attorney‑client privilege / notice / authentication) | Call contained privileged trial strategy; Reid had no notice call was recorded; recordings not properly authenticated | Reid waived privilege by disclosing attorney conversation to her mother; jail plays automated warning and system authenticated by technician testimony | Affirmed — disclosure waived privilege; automated warning provided notice; technician testimony and system description sufficiently authenticated recordings |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (sufficiency of evidence standard for convictions)
- Miranda v. Arizona, 384 U.S. 436 (Miranda custodial‑interrogation warnings rule)
- Jackson v. Denno, 378 U.S. 368 (requirement for voluntariness/Jackson‑Denno hearing when timely raised)
- Massiah v. United States, 377 U.S. 201 (Sixth Amendment prohibition on deliberate elicitation after post‑arraignment proceedings have begun)
- Brewer v. Williams, 430 U.S. 387 (Massiah line on Sixth Amendment protections)
- Wainwright v. Sykes, 433 U.S. 72 (failure to preserve certain claims may foreclose sua sponte hearing requirement)
- State v. Troutman, 300 Ga. 616 (Miranda presumption distinct from due‑process voluntariness analysis)
- Kemp v. State, 303 Ga. 385 (Sixth Amendment right to counsel tied to initiation of judicial proceedings)