State v. Estrada, 300 Ga. 199

On Nov. 7, 2013, 18-year-old Tyler Estrada (appellee) was in DeKalb County custody when Gwinnett County investigators questioned him about a Gwinnett homicide. Two audio recordings of custodial interviews were introduced at the suppression hearing.
At the start of the first recording, an investigator read Miranda warnings; Estrada did not waive his rights then. About five minutes in, Estrada said he did not want to talk about Gwinnett matters without a lawyer.
The lead investigator continued, threatened arrest for felony murder the next day to induce conversation, and later said he would give Estrada minutes to decide; Estrada again said he wanted an attorney and then made a few inculpatory statements.
Approximately eight minutes after the first invocation of counsel, officers stopped the first recording and left Estrada alone. After 5–6 minutes, they returned and began a second recorded interview (no waiver or attorney request retraction occurred); Estrada made extensive incriminating statements over an hour.
The trial court found Estrada had unequivocally invoked his right to counsel and never waived Miranda rights; it granted suppression of the custodial statement. The State appealed; the Supreme Court of Georgia affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers violated Miranda by continuing interrogation after an invocation of counsel	Estrada: he unequivocally invoked counsel; interrogation should have ceased	State: questioning resumed after a break and produced statements; waiver or reinitiation occurred	Court: Invocation was unequivocal; officers impermissibly continued interrogation, so statements suppressed
Whether statements during the second recording were admissible as a valid waiver or reinitiation	Estrada: he never waived or reinitiated; officers left the room and he did not ask them to return	State: investigators contend subsequent questioning and statements show reinitiation/waiver	Court: No verbal or written waiver and no reinitiation by Estrada; post-invocation police-initiated questioning invalidated any purported waiver

State v. Allen, 298 Ga. 1 (discusses review of suppression hearing and use of uncontradicted audio evidence)
State v. Sammons, 283 Ga. 364 (police must cease interrogation after invocation of counsel)
Gissendaner v. State, 269 Ga. 495 (reinforces requirement to stop questioning after counsel invoked)
Edwards v. Arizona, 451 U.S. 477 (once counsel is requested, interrogation must cease until counsel is provided or defendant initiates further communication)
Miranda v. Arizona, 384 U.S. 436 (custodial interrogation requires warnings and valid waiver of rights)