State v. Parker, 144 So. 3d 700

Michael Parker was interviewed by police after being Mirandized at his apartment and voluntarily accompanied officers to the station; he acknowledged his rights and agreed to talk.
During the station interview, Parker asked prefatory questions about whether he needed a lawyer and whether a lawyer was in the building; the detective responded "Listen, that’s your right. But what I’m interested in is the truth" and "No, you would have to call one."
Parker made incriminating statements after those exchanges, later called his father, and was arrested at the end of the interview.
At the suppression hearing, the trial court found Parker made at least two attempts to request counsel, that the detective “steamrolled” and overrode him, and suppressed statements made after the prefatory questions.
The State appealed; the majority reversed the suppression order, holding the detective gave good-faith, straightforward answers under Almeida v. State; a dissent argued the trial court’s factual findings merited deference and the suppression should be affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Parker)	Held
Whether detective failed to make a good-faith, simple answer to a prefatory question about counsel (Almeida test)	Detective’s replies informed Parker of his right and were simple, honest, and invited him to choose; Almeida satisfied	Detective’s prefatory questions sought legal assistance and were overridden; answers were evasive or steamrolling, violating Almeida	Reversed suppression: detective’s responses were simple, straightforward, and true under Almeida, so interrogation need not stop
Whether appellate court must defer to trial court’s factual findings about whether Parker requested counsel and was steamrolled	Majority: trial court’s factual findings accepted but misapplied legal standard; application of Almeida is reviewed de novo	Dissent: trial court’s factual findings (that Parker sought counsel and was prevented from calling) are supported and entitled to deference; suppression should be affirmed	Majority: legal application was incorrect; reversal. Dissent would affirm based on deference to trial judge’s credibility and fact findings

Miranda v. Arizona, 384 U.S. 436 (1966) (suspect’s rights to counsel and silence during custodial interrogation)
Almeida v. State, 737 So.2d 520 (Fla. 1999) (officer must give a good-faith, simple answer to a suspect’s clear question about rights before resuming interrogation)
State v. Glatzmayer, 789 So.2d 297 (Fla. 2001) (officers’ truthful, simple responses satisfy Almeida; no gamesmanship)
Traylor v. State, 596 So.2d 957 (Fla. 1992) (interrogation coercion concerns motivating Miranda/Almeida principles)
Walker v. State, 957 So.2d 560 (Fla. 2007) (equivocal or ambiguous requests for counsel do not require cessation of questioning)
Jones v. State, 748 So.2d 1012 (Fla. 1999) (statements that do not clearly invoke counsel are not unequivocal requests)