State v. Walden, 311 Ga. 389

April 28, 2019: Carly Walden called police after her mother was shot; she was later charged with malice murder and other crimes.
Deputy Sydnor arrived at the scene; Walden rode in his patrol vehicle to the sheriff’s office, unhandcuffed, carrying her phone, and was told she was "not in any type of trouble."
At the sheriff’s office Walden and Sydnor waited in an interview room (door open) for an investigator; Sydnor largely did not question her and did not handcuff her; she did not ask to leave on the recording.
Investigator Clinton French interviewed Walden without Miranda warnings; during a <6-minute exchange Walden said she had accidentally shot her mother; French stopped the interview. Later (hours after) French gave Miranda warnings and Walden requested counsel; she was handcuffed around 3:00 p.m.
Walden moved to suppress pre-Miranda statements made in the interview room; the trial court suppressed those statements without making explicit findings; the State appealed. The encounters were captured on video, enabling de novo review of controlling facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Walden was "in custody" for Miranda purposes when she made pre-Miranda statements in the interview room	State: Not in custody — she agreed to ride, was unhandcuffed, told not in trouble, waited with door open, did not request to leave on video	Walden: In custody — deputy detained her, impeded exit (uniformed, armed, nearby), told she could not leave, questioned in interview room	Court: Reversed suppression — objective totality of circumstances (video) did not support custody; Miranda warnings were not required before the challenged statements

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warnings required when person is in custody and subject to interrogation)
Howes v. Fields, 565 U.S. 499 (U.S. 2012) (factors for custody include location, duration, restraints, release)
J.D.B. v. North Carolina, 564 U.S. 261 (U.S. 2011) (subjective age and mindset have limited relevance; custody is assessed objectively)
State v. Troutman, 300 Ga. 616 (Ga. 2017) (custody exists if formally arrested or restrained to degree associated with formal arrest)
Licata v. State, 305 Ga. 498 (Ga. 2019) (totality-of-circumstances test; consider location, duration, statements, restraints, release)
McAllister v. State, 270 Ga. 224 (Ga. 1998) (assurance of not being under arrest supports non-custodial finding)
Sosniak v. State, 287 Ga. 279 (Ga. 2010) (custody not shown where handcuffs removed, defendant told not under arrest, questioned in unlocked room)