State v. Troutman, 300 Ga. 616

Investigators brought Andrew Troutman to police headquarters during a murder investigation and interviewed him three times over roughly nine hours; at the end of the third interview he confessed.
Troutman was never given Miranda warnings, was held in a non-public area, had his phone and shoes taken, was kept incommunicado, and was told on two occasions he was not free to leave.
Troutman was 21, still in high school, dyslexic, and reported not having slept in three days.
Troutman moved to suppress his inculpatory statement; the trial court found (a) he was in custody before the third interview so Miranda warnings were required, and (b) the statement was involuntary under due process.
The State appealed the voluntariness ruling but conceded Troutman was in custody only for Miranda purposes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Troutman was "in custody" so Miranda warnings were required	Troutman: sequestered, repeatedly interviewed, told he could not leave — reasonable person would feel restrained	State: not formally arrested; not restrained to degree of formal arrest	Court: A reasonable person in Troutman’s position would have believed he was in custody; Miranda required and unwarned statements before third interview suppressed
Whether the unwarned in-custody statement was involuntary under due process	Troutman: long detention, isolation, deprivation (phone/shoes), young, dyslexic, sleep-deprived — coercive tactics rendered confession involuntary	State: facts show custody but no coercive police activity equivalent to tactics that overcome free will; Elstad/Metheny line allows voluntariness despite Miranda violation	Court: Trial court erred; facts did not show coercive police conduct sufficient to render confession involuntary; statement not involuntary under due process

Miranda v. Arizona, 384 U.S. 436 (establishes custodial interrogation warnings)
Colorado v. Connelly, 479 U.S. 157 (coercive police activity is required to find a confession involuntary)
Oregon v. Elstad, 470 U.S. 298 (Miranda violation does not automatically make a statement coerced; statements may still be voluntary)
State v. Folsom, 286 Ga. 105 (custody analysis: sequestering and repeated questioning can create custody)
Sewell v. State, 283 Ga. 558 (reasonable-person custody standard)
Vergara v. State, 283 Ga. 175 (standard of review: trial court factual findings accepted unless clearly erroneous)
Metheny v. State, 197 Ga. App. 882 (Miranda presumption distinct from due process voluntariness; deliberate tactics needed to overcome will)
State v. Davison, 280 Ga. 84 (reversing involuntariness finding where coercive government activity was not shown)