Demetrius Bowman v. State

CourtCourt of Appeals of Georgia
DecidedNovember 15, 2013
DocketA13A1150
StatusPublished

This text of Demetrius Bowman v. State (Demetrius Bowman v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Demetrius Bowman v. State, (Ga. Ct. App. 2013).

Opinion

SECOND DIVISION BARNES, P. J., MILLER, and RAY, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

November 15, 2013

In the Court of Appeals of Georgia A13A1150. BOWMAN v. THE STATE.

BARNES, Presiding Judge.

Following the denial of his motion for new trial, Demetrius Bowman appeals

his convictions for armed robbery, aggravated assault, aggravated battery and three

counts of possession of a firearm during the commission of a crime.1 Bowman’s

convictions were the result of his involvement in a home invasion. On appeal,

Bowman does not challenge the sufficiency of the evidence. He contends instead that

his custodial statements were not knowing and voluntary and thus were admitted into

evidence in violation of his Fifth Amendment right against self-incrimination, and

that his trial counsel was ineffective. Upon our review, we affirm.

1. Bowman first asserts that his custodial statements were admitted in violation

of his Fifth Amendment right against self-incrimination. Bowman, who was 16 when

1 The aggravated assault conviction merged into the armed robbery count and the three possession of a firearm counts merged for sentencing purposes. he gave his custodial statement, contends that the trial court should not have

considered the factors set forth in Riley v. State, 237 Ga. 124, 128 (226 SE2d 922)

(1976), in ruling that this statements were admissible. Riley addresses a juvenile’s

waiver of his Miranda2 rights while in police custody, but Bowman contends that the

Riley factors do not apply here because his guardians did not consent in his presence

to his police interrogation. Bowman maintains that his custodial statements were not

knowing and voluntary because, as a minor, he should have been present when his

guardians consented to him being interviewed by the police. Because he was not

present when they consented, Bowman argues that he had no way of knowing what

his guardians had been told, whether they had been informed of his Miranda rights,

or whether they had actually consented at all.

While Bowman contends that Riley does not apply because his guardians did

not consent in his presence to the custodial interview, our Georgia Supreme Court

adopted the nine-factor analysis in Riley as a method for determining whether a

juvenile made a knowing and voluntary waiver of his right to remain silent when he

gave an incriminating statement outside his parents’ presence. Riley v. State, 237 Ga.

at 128. The presence or absence of a parent when the statement was made is simply

2 Miranda v. Arizona, 384 U.S. 436 (86 SC 1602, 16 LE2d 694) (1966).

2 one factor to be considered in determining whether the statement was voluntary and

admissible; it is not dispositive of the issue, as Bowman appears to suggest. See Allen

v. State, 283 Ga. 304, 306 (2) (a) (658 SE2d 580) (2008) (the fact that mother was not

present during custodial interview was a factor for the trial court to consider, but it

was not determinative on the issue of voluntariness). It is well accepted, however, that

confessions of juveniles must be scanned with more care and received with greater caution than those of adults. The question of a voluntary and knowing waiver depends on the totality of the circumstances, and the State has a heavy burden in showing that the juvenile did understand and waive his rights. However, as our Supreme Court has further explained, age alone is not determinative of whether a person can waive his rights. Instead, the question of waiver must be analyzed by a

consideration of several factors. Those factors include (1) age of the accused;

(2) education of the accused; (3) knowledge of the accused as to both the substance

of the charge and the nature of his rights to consult with an attorney and remain silent;

(4) whether the accused is held incommunicado or allowed to consult with relatives,

friends or an attorney; (5) whether the accused was interrogated before or after formal

charges had been filed; (6) methods used in interrogations; (7) length of

interrogations; (8) whether vel non the accused refused to voluntarily give statements

3 on prior occasions; and (9) whether the accused has repudiated an extra judicial

statement at a later date.

(Citations and punctuation omitted.) Boyd v. State, 315 Ga. App. 256, 256-257 (1)

(726 SE2d 746) (2012).

Here, after the victim of a home invasion identified Bowman from his

nickname “Peanut” and in a photographic lineup, police stopped the car in which

Bowman was riding with his uncle and arrested him. The police impounded the car,

but drove Bowman’s uncle home. There, they told the uncle and grandmother, who

were Bowman’s guardians, about Bowman’s suspected involvement in the home

invasion, and received consent to search Bowman’s room and consent to question

Bowman. Police recovered a gun under Bowman’s mattress, and his uncle told the

officers that he knew the gun had not been there a few days before because he had

changed the sheets on the bed.

Bowman was interviewed at the police station after being read his juvenile

Miranda rights and consenting to the interview. He denied having anything to do with

the robbery. He also said that he had not been on the street where the incident

occurred for four months, denied having the nickname “Peanut,” and denied having

a weapon. He later admitted to being on the victim’s street the day before the home

4 invasion and that he was sometimes called “Peanut.” He also told officers that he had

a gun and that he had purchased it as protection from a drug dealer to whom he owed

money.

After conducting a hearing pursuant to Jackson v. Denno, 378 U. S. 368 (84

SCt 1774, 12 LE2d 908) (1964), the trial court applied the Riley analysis and

concluded that Bowman’s statement was admissible. The evidence demonstrated that

Bowman was four months shy of his 17th birthday, and that he appeared to

understand his juvenile Miranda rights when an officer explained them to him,

including the right to talk with an attorney and have an attorney present when he was

questioned. Bowman also read the juvenile Miranda rights out loud, and appeared to

understand the charges against him. He told officers that he would talk with them

without a lawyer present, and did not request the presence of his grandmother or

uncle during the interview. The officers testified that there were no offers or promises

made to Bowman in exchange for his statements, nor were there threats of injury. The

interview lasted approximately 35 to 45 minutes. Bowman does not repudiate the

truth of his statements, but instead challenges their admissibility based on the alleged

absence of a valid consent in the presence of his guardians.

In these circumstances,

5 [t]he trial court was entitled to determine the credibility of the witnesses and to believe the officers, and its findings were not clearly erroneous. That [Bowman] was interviewed outside the presence of his [guardian], although a factor to be considered by the trial court, did not preclude the admission of his statement. . . .

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Related

Jackson v. Denno
378 U.S. 368 (Supreme Court, 1964)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Sims v. State
640 S.E.2d 260 (Supreme Court of Georgia, 2007)
Jackson v. State
592 S.E.2d 834 (Supreme Court of Georgia, 2004)
Gordian v. State
581 S.E.2d 616 (Court of Appeals of Georgia, 2003)
Killings v. State
676 S.E.2d 31 (Court of Appeals of Georgia, 2009)
Sweet v. State
602 S.E.2d 603 (Supreme Court of Georgia, 2004)
Riley v. State
226 S.E.2d 922 (Supreme Court of Georgia, 1976)
Rivers v. State
657 S.E.2d 210 (Supreme Court of Georgia, 2008)
Allen v. State
658 S.E.2d 580 (Supreme Court of Georgia, 2008)
Boyd v. State
726 S.E.2d 746 (Court of Appeals of Georgia, 2012)
Jones v. State
727 S.E.2d 216 (Court of Appeals of Georgia, 2012)

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Demetrius Bowman v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/demetrius-bowman-v-state-gactapp-2013.