Walker v. State, 312 Ga. 332

Walker was charged and convicted of the January 24, 2016 murders of Jaquille Thomas and Angelique Bowman; he did not testify at trial.
About 20 minutes into a recorded custodial interview, Detective Brucz read Walker his Miranda rights; Walker indicated he understood and agreed to talk.
Approximately 1 hour 9 minutes into the interview Walker made admissions that he shot both victims; the interview was video-recorded and a redacted recording was played at trial.
In a post-trial motion Walker claimed, for the first time, that he had invoked his right to remain silent during the interview when he allegedly said (mumbling) “I just want to go to jail. I don’t wanna talk no more” and later “I don’t even wanna talk.”
The trial court, after reviewing the recording and hearing witnesses, found those utterances were mumbling/ambiguous and not clear, unambiguous invocations; it admitted the statements and denied the suppression/new-trial motion.
On appeal the only issue raised was plain-error review of the trial court’s ruling; the Supreme Court of Georgia affirmed, deferring to the trial court’s factual finding that the purported invocations were not clear and unequivocal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Walker’s custodial confessions should have been suppressed because he invoked his Miranda right to remain silent	Walker: He twice said he did not want to talk, so interrogation should have ceased	State: Utterances were mumbled/ambiguous; officers reasonably did not perceive an invocation; claim was unpreserved so reviewed for plain error	Court: Affirmed — trial court’s finding that statements were not clear and unequivocal was not clearly erroneous; no plain error

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings and right to remain silent)
Jackson v. Denno, 378 U.S. 368 (1964) (procedure for determining voluntariness of confessions)
Davidson v. State, 304 Ga. 460 (2018) (invocation must be unambiguous and unequivocal such that a reasonable officer would stop questioning)
State v. Clark, 301 Ga. 7 (2017) (defer to trial-court factual findings on suppression; limited de novo review of videotape where facts are indisputable)
McKinney v. State, 307 Ga. 129 (2019) (explains plain-error standard for unpreserved issues)
State v. Herrera-Bustamante, 304 Ga. 259 (2018) (summarizes elements of plain-error review)
State v. Mohammed, 304 Ga. App. 230 (2010) (video-review de novo only for indisputably discernible facts)
Raheem v. State, 275 Ga. 87 (2002) (inaudible or mumbled statements do not constitute an invocation of rights)