Williams v. State, 301 Ga. 60

Deputy Wesley Aaron approached Michael Williams while investigating a burglary; during the encounter Williams fled.
Deputy Aaron arrested Williams for obstruction after Williams fled; Williams was advised of Miranda rights at the jail and then made statements implicating himself in the burglary.
Williams was indicted for burglary and obstruction and moved to suppress his post-arrest statements.
At the Jackson-Denno hearing Deputy Aaron was the sole witness; the trial court found the encounter was a first-tier encounter and the subsequent arrest for obstruction lacked probable cause, suppressing the statements.
The Court of Appeals reviewed the hearing transcript, made additional factual findings (e.g., Williams was "agitated and fidgety," fled when told he was a suspect), concluded a second-tier stop and probable cause supported the arrest, and reversed the suppression.
The Georgia Supreme Court vacated the Court of Appeals decision and remanded because the trial court’s written findings were too sparse to permit meaningful appellate review of credibility and factual determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arrest was lawful (obstruction/probable cause)	Williams: flight during a first-tier encounter was lawful; arrest lacked probable cause; statements inadmissible	State: transcript shows additional facts (agitation, flight upon being told he was suspected) constituting "other circumstances" to justify second-tier stop and provide probable cause for arrest	Court did not decide substance; vacated Court of Appeals reversal because trial court’s factual findings were insufficiently detailed for appellate review and remanded for clarification
Proper scope of appellate review of suppression rulings	Williams: trial court is factfinder; its findings should be accepted unless clearly erroneous	State: Court of Appeals relied on hearing testimony and made its own factual findings to reverse	Court reiterated that appellate courts must accept trial court’s express findings, construe record favorably to those findings, and limit review to facts the trial court expressly found; remand required when findings are too sparse

State v. Williams, 336 Ga. App. 97 (Court of Appeals decision reversed) (appeal addressed legality of arrest and suppression ruling)
Hughes v. State, 296 Ga. 744 (clarifying appellate review limits when trial court makes express factual findings)
Jones v. State, 291 Ga. 35 (describing the three tiers of police-citizen encounters)
Lee v. State, 270 Ga. 798 (example where flight and contextual facts supported reasonable suspicion)
Parker v. State, 255 Ga. 167 (remand for further findings when trial court’s findings are insufficient)