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proposition that “ a waiver of Miranda rights may be implied through ‘the defendant's silence, coupled with an understanding of his rights and a course of conduct indicating waiver.’ 441 U.S., at 373.” Here, no contention that defendant didn’t understand his rights; and majority finds defendant’s brief answers, quoted above, to establish “a course of conduct indicating waiver.” “This is confirmed by the fact that before then Thompkins had given sporadic answers to questions throughout the interrogation.” Contrary to defendant’s assertion, express waiver is not required before interrogation commences. “The Miranda rule and its requirements are met if a suspect receives adequate Miranda warnings, understands them, and has an opportunity to invoke the rights before giving any answers or admissions. Sotomayor writes for four dissenters, decrying the loosening of Miranda ’s standard that “courts must presume that a defendant did not waive his rights; the prosecution's burden is great.” Dissent finds it illogical, and not readily apparent to defendants from Miranda warnings, that to invoke the right of silence, they must speak, as contrasted with the right to counsel in Davis ; and cites to numerous lower court decisions finding ambiguity in apparently-clear invocations of right to silence, see fn. 9. Accord, Barnes (June 28, 2010), and Law (February 24, 2011), above. See also Salinas (June 17, 2013), above (may comment on pre-arrest silence absent express invocation of Fifth Amendment privilege). State v. Moon, 285 Ga. 55, 673 S.E.2d 255 (February 23, 2009). Trial court properly suppressed defendant’s custodial statement made after defendant unambiguously “invoked his right to remain silent” by stating “I ain't got no more to say. I mean, that is it.” Officers ignored defendant’s repeated statements that he wished to end the interrogation. Trial court erred, however, in suppressing statements made by defendant prior to invoking his right to remain silent. Accord, Frazier v. State , 298 Ga.App. 487, 680 S.E.2d 553 (June 23, 2009) (Defendant’s conviction for aggravated assault reversed; trial court erred in admitted defendant’s custodial statement made after defendant “repeatedly stated that he did not want to talk to anyone and asked to speak to his lawyer.”); Arrellano-Campos v. State , 307 Ga.App. 561, 705 S.E.2d 323 (January 19, 2011) (stipulating to statement given in similar circumstances was deficient representation, but harmless where defendant re-initiated conversation with officer later). Webb v. State, 284 Ga. 122, 663 S.E.2d 690 (July 7, 2008). When officer asked defendant to sign Miranda waiver, defendant responded, “I don’t want to talk about that,” and again, “I’m not willing to make a statement.” Officer continued to press for signature on waiver, however, and upon getting the signature, then asked defendant what happened. Defendant told him. Held, “[a]fter Webb made this unequivocal assertion of his right to remain silent, all questioning of Webb should have ceased. Green v. State, 275 Ga. 569(2) (570 S.E.2d 207) (2002). … However, it is also true that, because Webb's testimony at trial was consistent with his custodial statement, ‘any error in admitting the statement would have to be deemed harmless.’ (Citation omitted.) Larry v. State, 266 Ga. 284, 286(2)(a) (466 S.E.2d 850) (1996).” Griffin v. State, 280 Ga. 683, 631 S.E.2d 671 (June 26, 2006). Defendant invoked his right to remain silent during custodial statement; officer honored his request and left. Three days later, officer returned to jail, re-read Miranda , and defendant agreed to give statement. Held, trial court properly admitted resulting statement. “Relying on Edwards v. Arizona, 451 U.S. 477 (101 S.Ct. 1880, 68 L.Ed.2d 378) (1981), Griffin contends that the second round of questioning was inappropriate. Edwards, however, addresses the propriety of continued questioning after a defendant has invoked his right to counsel, and, as Griffin invoked only his right to remain silent in this case, Edwards is not applicable here. See Fields v. State, 266 Ga. 241(1) (466 S.E.2d 202) (1996) (second interrogation regarding same crime was proper after ten months had elapsed). When a defendant has invoked his right to remain silent, as Griffin did, the propriety of subsequent custodial questioning is governed by Michigan v. Mosley, 423 U.S. 96 (96 S.Ct. 321, 46 L.Ed.2d 313) (1975). In Mosley, subsequent custodial interrogation was admissible where the initial invocation of the right to remain silent was ‘scrupulously honored,’ a significant period of time had passed, Miranda warnings were repeated, and the second interrogation concerned a different crime. Id. at 106. A second interrogation regarding the same crime may also be constitutional under Mosley, however, where the initial invocation of the right to remain silent was scrupulously honored. Fields, supra.” “Compare Wilson v. State, 275 Ga. 53(2) (562 S.E.2d 164) (2002) (18 hours between interviews regarding same crime not significant where initial invocation of right to silence was not scrupulously honored).” Hunter v. State, 273 Ga.App. 52, 614 S.E.2d 179 (April 20, 2005). “Hunter … alleges that the trial court erred by admitting in evidence a Miranda rights warning form that showed he refused to sign the form. Hunter moved for a mistrial, but his motion was denied. The evidence shows, however, that Hunter was warned of his rights and that he made a statement to the police. Nevertheless, Hunter now contends that admitting the rights waiver form showing that he refused to sign it violated his right against self-incrimination. We find no merit to this argument because ‘refusal to sign a waiver form does not constitute an invocation of the right to remain silent or the right to counsel.’ Aldridge v. State, 258 Ga. 75, 76(3) (365 S.E.2d 111) (1988).” Presumably, the document would have been inadmissible had defendant
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