State v. Austin, 310 Ga. App. 814

Cobb County officers respond to a neighbor's report of shots fired at Austin's home; they approach with weapons drawn and identify two men in the driveway.
Austin emerges from the garage appearing angry; he is handcuffed for officer safety during the encounter.
Austin invites officers inside to view a handgun he claims to fired; he leads them to a bedroom where the gun is beneath the mattress.
Officers observe a small amount of marijuana on a bedside table in plain view and question Austin about further contraband in the house.
Austin leads officers through the home, revealing additional firearms; marijuana and guns are subsequently seized.
Austin is arrested after exiting the home and is indicted for felony marijuana possession and firearm during a crime; he moves to suppress the evidence and statements obtained.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the searches and seizures were lawful despite the suppression order	Austin consented to entry and limited search, making subsequent seizures lawful	Consent to search was not freely voluntary for expanded searches after initial seizure	Partially affirmed; handgun and plain-view marijuana conceded; further searches suppressed
Whether statements made after handcuffing were admissible under Miranda	Statements made while not formally arrested should be suppressed as custodial	Handcuffed but not formally arrested, thus some statements were admissible	Admitted some statements before marijuana found; suppressed statements after plain-view marijuana discovery
What standard of review applies to suppressed-evidence findings on appeal	Undisputed evidence supports de novo review per Vansant/ Davis line of cases	Custodial determinations and credibility require deferential review	Affirmed in part and reversed in part; de novo review applied to undisputed portions; credibility matters persisted

Miranda v. Arizona, 384 U.S. 436 (Supreme Court 1966) (Miranda warnings framework for custody and interrogation)
Jourdan v. State, 264 Ga. App. 118 (Ga. App. 2003) (consent and voluntariness standards for searches; scope of consent)
Vansant v. State, 261 Ga. 225 (Ga. 1991) (origin of de novo review for undisputed evidence in suppression appeals)
Davis, 261 Ga. 225, 404 S.E.2d 100 (Ga. 1991) (footnote cited for Vansant-de novo review standard; caution on precedent)
Tate v. State, 264 Ga. 53 (Ga. 1994) (trier of fact credibility and belief of testimony; relevance to suppression review)
McTaggart, 241 Ga. App. 852 (Ga. App. 2000) (plain-view doctrine and scope of consent to search)