Teele v. State, 319 Ga. App. 448

Teele was convicted of armed robbery, based on evidence Williams allegedly robbed the victim with Teele in the car.
The incident occurred January 6, 2011 when Williams approached the victim at a gas station, discussed jewelry, and arranged a meet so Teele could view it.
Teele drove a red Dodge Neon with Williams as front-seat passenger; the victim handed Williams a necklace, then Williams threatened him with a gun and drove off.
The victim identified Teele at the scene; the officer stopped the vehicle, Teele was detained at gunpoint, and she initially resisted orders to exit the car.
Williams pleaded guilty and testified for Teele, claiming Teele did not participate; Teele appealed asserting insufficiency of the evidence and suppression issues.
On appeal, Teele challenged admission of her custodial statement to police and exclusion of her co-defendant’s prior sworn statement, while the court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Teele argues insufficient evidence to prove party to armed robbery.	State contends the evidence shows Teele aided and abetted Williams.	Evidence sufficient to support conviction
Miranda custody/interrogation	Teele argues her unwarned custodial statement should have been suppressed.	State argues no custodial interrogation occurred for Miranda purposes.	Statement admissible; no Miranda violation
Effect of excluding planned cross-examination	Teele contends exclusion of questions to Williams could exonerate her.	State argues questions were irrelevant and error harmless.	No reversible error; harmless

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard: any rational juror could find elements beyond reasonable doubt)
Burks v. State, 268 Ga. 504 (Ga. 1997) (party liability; presence at scene not enough; intent inferred from conduct)
Jordan v. State, 281 Ga. App. 419 (Ga. App. 2006) (evidence supports party to crime finding even if not primary actor)
Hesrick v. State, 308 Ga. App. 363 (Ga. App. 2011) (standards for appellate review of suppression rulings; de novo/apply facts)
Waters v. State, 281 Ga. 119 (Ga. 2006) (custody under Miranda when in police custody in relevant interrogation)
Nickerson v. State, 248 Ga. App. 829 (Ga. App. 2001) (police query for identity of suspect not custodial interrogation)
Cook v. State, 270 Ga. 820 (Ga. 1999) (definition of interrogation and when questioning crosses line)
Michigan v. Bryant, 131 S. Ct. 1143 (U.S. 2011) (testimonial vs nontestimonial statements; on-point for custody/interrogation distinction)
Franks v. State, 268 Ga. 238 (Ga. 1997) (booking exception and interrogation analysis related to Miranda)
Bowens v. State, 276 Ga. App. 520 (Ga. App. 2005) (harmless error guidance in exclusion of evidence)