State v. Rumph, 307 Ga. 477

Victim Jerry Whitten was found shot to death; Christopher Rumph was the last person known to see him alive and was contacted by investigators.
Investigator Sgt. Ryan Whittle interviewed Rumph at Rumph’s home (audio-recorded); Rumph consented to searches and described his movements that night; no Miranda warnings were given.
Investigators then accompanied Rumph to the nursery and later asked him to give a video-recorded statement at the sheriff’s substation; Rumph rode voluntarily, kept his keys and phone, took breaks, received phone calls, and was allowed to leave.
During the substation interview Rumph asked for a lawyer; questioning paused, Rumph ultimately left; investigators later obtained a search warrant for Rumph’s home, found a handgun and casings, and arrested him for being a felon in possession.
After arrest Rumph gave a third, Mirandized, video-recorded statement in which he waived rights and claimed a mental condition; trial court admitted this third statement but suppressed the first two as custodial statements made without Miranda warnings.
The State appealed the interlocutory suppression order; the Georgia Supreme Court reversed, holding the first two interviews were noncustodial and Miranda warnings were not required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rumph’s first two statements were custodial so that Miranda warnings were required	Statements were noncustodial; Rumph voluntarily spoke at home and at the substation	Statements were custodial; restraints and station environment made a reasonable person feel not free to leave	The statements were noncustodial; Miranda not required and suppression was erroneous
Whether the third, post-arrest statement was admissible	Third statement was custodial but voluntarily made after Miranda warnings and waiver	(No appeal of the admission)	Trial court properly admitted the third statement as freely and voluntarily given

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warning requirement for custodial interrogation)
Jackson v. Denno, 378 U.S. 368 (1964) (procedures for determining voluntariness of confessions)
Norwood v. State, 303 Ga. 78 (2018) (trial court’s factfinding and preponderance standard for defendant statements)
Hughes v. State, 296 Ga. 744 (2015) (appellate deference to trial-court factual findings and recorded evidence exceptions)
Freeman v. State, 295 Ga. 820 (2014) (Miranda warnings required only when person is formally arrested or restrained like an arrest)
Drake v. State, 296 Ga. 286 (2014) (pre-Miranda statements admissible where interview was voluntary and noncustodial)