Williams v. State, 301 Ga. 60

Deputy Wesley Aaron approached Michael Williams while investigating a burglary; Williams fled during the encounter.
Deputy Aaron arrested Williams for obstruction (fleeing) and, after Miranda warnings at the jail, Williams made incriminating statements about the burglary.
Williams was indicted for burglary and obstruction and moved to suppress his post-arrest statements.
At the Jackson-Denno hearing the trial court heard only Deputy Aaron’s testimony and found Williams had fled a first-tier encounter, concluded the arrest lacked probable cause, and granted suppression.
The Court of Appeals reversed, finding additional facts in the record (Williams was “agitated and fidgety,” fled upon being told he was a suspect) that supported a second-tier stop and probable cause for arrest.
The Supreme Court vacated the Court of Appeals’ decision and remanded, holding the trial court’s order lacked sufficient factual findings to permit meaningful appellate review.

Issue	Williams' Argument	State's Argument	Held
Whether the arrest was lawful (first-tier vs. second-tier and probable cause)	Flight from a first-tier encounter was lawful; arrest lacked probable cause so statements should be suppressed	Officer’s testimony showed “other circumstances” (agitation, fleeing on being told he was a suspect) creating reasonable suspicion/ probable cause	The Court did not decide the merits; vacated COA opinion and remanded for clearer trial-court findings because trial court’s order lacked detail
Whether appellate court may make its own factual findings when trial court’s findings are insufficient	Trial court’s grant should be upheld unless findings are clearly erroneous; appellate courts must accept trial-court fact findings	COA relied on additional facts in record to reverse suppression	Supreme Court held appellate court erred to make new factual findings absent express trial-court findings and remanded for clarification
Whether suppression ruling was reviewable without more detailed factual findings	Suppression should stand based on trial court’s conclusion that arrest lacked probable cause	State argued facts supported a lawful arrest and statements admissible	Court required the trial court to clarify which facts it credited and the legal basis before appellate review

Hughes v. State, 296 Ga. 744 (explaining appellate deference to trial-court factual findings on suppression)
Jones v. State, 291 Ga. 35 (describing three tiers of police-citizen encounters)
Lee v. State, 270 Ga. 798 (example where officer’s observations plus flight supported at least articulable suspicion)
Parker v. State, 255 Ga. 167 (remand for further findings when trial court’s factual findings are insufficient)
State v. Williams, 336 Ga. App. 97 (COA decision reversing suppression based on additional factual findings)