Defendant’s cousin, visiting the house and working in the garage, had no apparent authority to consent to an entry. He made it clear it wasn’t his house, that he had no key and entered through an unlocked side door, and that he was waiting for his cousin. State v. Holtzclaw, 2017 Ga. App. LEXIS 258 (June 8, 2017).
“Because Newell failed to sustain her initial burden of proof to demonstrate that her stop and seizure were warrantless and that her statements were the result of custodial interrogation, the trial court erred as a matter of law in granting her motion to suppress.” State v. Newell, 2017-Ohio-4143, 2017 Ohio App. LEXIS 2206 (1st Dist. June 7, 2017).*