State v. Lee, 298 Ga. 388

15-year-old Ceron Lee was identified as being with the victim around the time of a September 2006 shooting and was interviewed at police headquarters the next day.
Lee and several witnesses were interviewed beginning in the early afternoon; after initial interviews Lee became a suspect and a second interview was initiated around 11:00 p.m.
Lee’s mother was present for the second interview. Lee was visibly distraught—hunched, covering his face, sobbing, hyperventilating, and intermittently wailing throughout the roughly hour-long recorded session.
Officers presented a waiver form and asked Lee to read it aloud; his mother began reading and then said Lee needed a lawyer. Lee did not sign the form, acknowledge understanding, or verbally waive rights.
Despite Lee’s distress and lack of affirmative waiver, officers continued questioning and described shooting details until Lee, encouraged by his mother and between sobs, began answering.
Trial court suppressed the custodial statement, finding Lee did not knowingly and intelligently waive Miranda rights; State appealed under OCGA § 5-7-1(a)(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lee, a 15-year-old, knowingly and intelligently waived constitutional (Miranda) rights before giving a custodial statement	The State: waiver is valid because officers read the form and questioning produced statements	Lee: his age, extreme distress, failure to sign or acknowledge the form, and lack of affirmative waiver show no knowing/intelligent waiver	Court: No waiver — suppression affirmed

Mack v. State, 296 Ga. 239 (review standard de novo when facts undisputed on appeal)
Norris v. State, 282 Ga. 430 (juvenile waiver assessed under totality of circumstances)
State v. Rodriguez, 274 Ga. 728 (State bears heavy burden proving juvenile waiver; parental assent insufficient)
Fare v. Michael C., 442 U.S. 707 (juvenile waiver requires assessment of age, experience, education, background, intelligence)