The Supreme Court of Georgia has upheld the murder conviction and life sentence of Stephan Blake Dickey, the Fannin County defendant found guilty in the 2018 killing of Justin McKinney in Morganton. In a decision handed down Tuesday, the court rejected defense arguments that Dickey, who was 15 at the time, did not knowingly waive his Miranda rights before giving a statement to investigators.
In a written opinion, the court said the trial judge correctly used the "totality of the circumstances" test and concluded that Dickey's confession was voluntary, according to the Supreme Court of Georgia. The opinion notes that a jury convicted Dickey at the end of a 2022 trial, after which he was sentenced to life in prison. The justices declined to send the case back for more factual findings and affirmed the trial court's decision denying suppression of his statement.
What Happened In Morganton
Investigators say an early-morning attack on December 4, 2018, left 33-year-old Justin McKinney dead and Anna Franklin wounded, and agents announced arrests that same day, according to the Georgia Bureau of Investigation. Prosecutors told jurors the group had planned to rob and kill the victims, and court records show that a .410 shotgun recovered from a co-defendant’s mattress and a .25-caliber pistol pulled from a nearby lake matched shell casings found at the scene, as detailed in Hill v. State. Tests also found gunshot residue on Dickey’s hands and sweatshirt.
Where The Co-Defendants Landed
One co-defendant, Hunter Hill, was tried separately, convicted of malice murder, and later had those convictions affirmed on appeal. Other members of the group either pleaded out or were convicted on related charges. According to FOX 5 Atlanta, Dalton Manuel was convicted of aggravated assault and is serving time, while Lakota Cloer was convicted of aggravated assault and is currently on parole.
How The Justices Viewed Miranda For Minors
In addressing the Miranda issue, the court reiterated that "the waiver must be voluntary in the sense that it was the product of a free and deliberate choice," and emphasized that judges have to look at the full context when weighing statements given by juveniles, according to the Supreme Court of Georgia. The ruling leaves Dickey's life sentence in place and spells out how Georgia courts are to review Miranda waivers by minors going forward.
