State v. Kendrick, 309 Ga. App. 870

Kendrick charged with burglary of a dwelling with intent to commit theft.
Patrol officer detained Kendrick after verifying he had no ID; Kendrick was handcuffed and questioned without Miranda warnings.
Kendrick provided the fan's origin and location at a pile of trash, eventually admitting taking it from an open doorway of a nearby abandoned house.
Backup officer monitored Kendrick while officers investigated the abandoned house; the patrol officer planned to take Kendrick to the precinct for the investigator.
Investigator provided Miranda warnings after Kendrick was transported to the precinct; Kendrick then gave a statement to the investigator largely mirroring the prior admission.
Trial court granted suppression of the patrol officer’s unwarned statements; the state appealed only to the admissibility of the post-warning confession to the investigator, which the court ultimately found inadmissible under Seibert/Pye

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post-handcuffing statements to the patrol officer were admissible.	Kendrick	Kendrick	Admissibility denied; custodial interrogation without warnings
Whether Kendrick’s post-warning confession to the investigator is admissible under Seibert/Pye/Elstad.	State	Confession should be admissible under Elstad after warnings	Not admissible; midstream warnings ineffective; two-stage interrogation impermissible

Seibert v. United States, 542 U.S. 600 (U.S. 2004) (two-stage interrogation invalid when warnings follow unwarned confession)
Pye v. State, 282 Ga. 796 (Ga. 2007) (Seibert framework applied to Georgia cases; midstream warnings ineffective)
Elstad v. Oregon, 470 U.S. 298 (U.S. 1985) (midstream warnings may be ineffective depending on circumstances)
Timmreck v. State, 285 Ga. 39 (Ga. 2009) (contextual analysis of post-Miranda statements in Seibert framework)
Grayer v. State, 282 Ga. 224 (Ga. 2007) (Seibert-related admissibility considerations in Georgia)