No Per Se Miranda Custody for 10-13 Behavioral Health Interviews; Pattern Insanity and Intoxication Instructions Suffice

Commentary on Gravitt v. State, Supreme Court of Georgia (Decided Oct. 21, 2025)

Introduction

In Gravitt v. State, the Supreme Court of Georgia addressed two recurrent but often misunderstood intersections of criminal procedure and mental health law: (1) whether an interview conducted by law enforcement at a behavioral health facility (in the context of an apparent civil mental-health hold, colloquially a “10-13”) is “custodial” for Miranda purposes, and (2) whether, and to what extent, trial courts must deliver non-pattern jury instructions on insanity—particularly delusional compulsion—and voluntary intoxication.

The case arose from the stabbing death of Glenn Fraser. The defendant, Cameron Marshall Gravitt, conceded he was the killer but pursued a not guilty by reason of insanity (NGRI) defense. A jury rejected NGRI and instead found him guilty but mentally ill (GBMI) of malice murder and guilty of possession of a knife during the commission of a felony. On appeal, Gravitt challenged (a) the admission of statements he made to detectives while at Highland Rivers, a behavioral health facility, prior to the administration of Miranda warnings, and (b) the trial court’s refusal to give several non-pattern jury charges geared toward his insanity defense and the role of voluntary intoxication.

The Supreme Court affirmed, clarifying that there is no per se Miranda custody arising from a mental-health facility interview—even if the interviewee is under an involuntary mental-health hold—and that Georgia’s pattern jury instructions on delusional compulsion and voluntary intoxication sufficiently state the law absent circumstances warranting additional, non-duplicative charges.

Summary of the Opinion

The Court held:

• The pre-Miranda interview at Highland Rivers was not custodial under Miranda. Applying the totality-of-the-circumstances test, the Court emphasized that Gravitt was not restrained, was repeatedly told he did not have to speak, was not isolated from staff, and the questioning lasted approximately 35 minutes. Even assuming a civil mental-health hold (a “10-13”) was in effect, that status did not transform the setting into Miranda custody. Further, officers’ uncommunicated suspicions or plans to arrest do not create custody (citing Stansbury v. California, 511 U.S. 318 (1994); Minnesota v. Murphy, 465 U.S. 420 (1984)).
• The trial court did not err by refusing the defense’s requested modifications to the delusional compulsion charge drawn from Lawrence v. State, 265 Ga. 310 (1995). The court’s use of the pattern charge accurately stated the law, which requires that a delusion excuse criminal liability only if the delusion, if true, would have justified the act (OCGA § 16-3-3).
• The court correctly refused to give the non-pattern “utterly senseless and abnormal” act charge from Brown v. State, 228 Ga. 215 (1971), because the trial court had already charged on insanity; where an insanity instruction is given, Brown is not required (see Bennett v. State, 262 Ga. 149 (1992)).
• The court properly declined additional non-pattern instructions on voluntary intoxication. The pattern charges adequately explained that voluntary intoxication is not a defense unless there is a more-than-temporary alteration of brain function that negates intent (Guyes v. State, 286 Ga. 574 (2010); Scott v. State, 275 Ga. 305 (2002); Hayes v. State, 262 Ga. 881 (1993)).

Result: Convictions affirmed; no Miranda violation; no instructional error.

Factual and Procedural Background

The record showed that on the morning of August 31, 2021, Gravitt displayed disorganized behavior at work and left around 8:09 a.m. It is undisputed he later went to Fraser’s office and fatally stabbed him. Around 1:00 p.m., he appeared at a bank, reported hearing voices, and was visibly fidgety and confused. Police initiated a traffic stop after a minor traffic violation and a welfare concern. On camera, Gravitt acknowledged hearing voices but initially declined medical evaluation, then agreed to go to a hospital. A search of his vehicle pursuant to warrant later revealed knives (one with blood), drug paraphernalia, and liquor bottles. His clothing bore blood that later matched the victim’s DNA.

On September 3, 2021, detectives interviewed Gravitt at Highland Rivers. He described hearing voices and a belief in “draco” shapeshifters; said the voices directed him to kill a supposed pedophile/cannibal; and described the stabbing. When an officer pointed to a stain on his pants and asked if it was the victim’s blood, he agreed. The officers then administered Miranda warnings; Gravitt invoked counsel; the interview ended. At trial, three psychologists testified about his mental condition, with the State’s expert diagnosing amphetamine-induced psychotic disorder tied to methamphetamine injection and opining he knew right from wrong. The defense expert opined psychosis persisted and that a delusional compulsion overmastered his will. The court-appointed expert could not evaluate because Gravitt denied the act during their meeting.

The jury found him GBMI of malice murder and guilty of possession of a knife during the commission of a felony. The trial court imposed life with possibility of parole on malice murder and a consecutive five-year term on the weapons count. On appeal, Gravitt challenged the admission of his pre-Miranda statements and the refusal to give certain non-pattern instructions on insanity and voluntary intoxication.

Analysis

Precedents Cited and Their Role

• Miranda and custody framework:
  • California v. Beheler, 463 U.S. 1121 (1983) and Thompson v. Keohane, 516 U.S. 99 (1995): Define “custody” under Miranda as formal arrest or restraint comparable to formal arrest, judged by whether a reasonable person would feel free to terminate the questioning and leave.
  • Howes v. Fields, 565 U.S. 499 (2012): No bright-line custody rule for interviews of persons already in state custody for other reasons; totality of circumstances governs.
  • State v. Walden, 311 Ga. 389 (2021) and Hayes v. State, 320 Ga. 505 (2024): Georgia applications of the custody inquiry and appellate standards.
  • Stansbury v. California, 511 U.S. 318 (1994); Berkemer v. McCarty, 468 U.S. 420 (1984); Minnesota v. Murphy, 465 U.S. 420 (1984): An officer’s unarticulated suspicions or plans do not create custody; the “focus of the investigation” alone is irrelevant to a noncustodial setting.
  • Jennings v. State, 282 Ga. 679 (2007); Robinson v. State, 278 Ga. 299 (2004); Whittaker v. State, 317 Ga. 127 (2023): Georgia cases holding that hospital interviews often are not custodial where the suspect is not restrained, not isolated, and is told they need not speak; these informed the Court’s analogy to a behavioral health facility.
• Insanity and delusional compulsion:
  • OCGA §§ 16-3-2, 16-3-3: Codify Georgia’s insanity defenses—(i) inability to distinguish right from wrong and (ii) delusional compulsion that overmasters the will.
  • Bowman v. State, 306 Ga. 97 (2019): Defendant bears burden (preponderance) to prove insanity.
  • Lawrence v. State, 265 Ga. 310 (1995): Endorses pattern instruction requiring that a delusion, if true, would justify the act.
  • Brown v. State, 228 Ga. 215 (1971): Approved a charge stating an act may be so senseless as to evidence a diseased mind; distinguished here because the trial court in Gravitt did charge insanity.
  • Bennett v. State, 262 Ga. 149 (1992): Where the court charges insanity, it may properly refuse the Brown language.
• Voluntary intoxication:
  • OCGA principles as distilled in pattern instructions: Voluntary intoxication is not a defense, except where a more-than-temporary alteration of brain function negates intent.
  • Guyes v. State, 286 Ga. 574 (2010); Scott v. State, 275 Ga. 305 (2002); Hayes v. State, 262 Ga. 881 (1993): Clarify that only a permanent or more-than-temporary impairment of brain function from intoxication can negate intent; temporary intoxication, even severe, does not excuse criminal acts.
• Jury-instruction standards:
  • Craft v. State, 321 Ga. 638 (2025); Thomas v. State, 297 Ga. 750 (2015); Eubanks v. State, 317 Ga. 563 (2023); Allaben v. State, 299 Ga. 253 (2016): Courts review the charge as a whole; refusal to give a requested instruction is not error if the substance is covered; de novo review applies to properly preserved claims.

Legal Reasoning

1) Miranda/Custody at a Behavioral Health Facility

The Court applied the objective, totality-based custody standard. Key facts:

• Location and setting: an intake room at Highland Rivers, provided by facility staff; Gravitt was escorted in by staff, not police.
• Physical restraint: none; no handcuffs; no evidence of isolation; staff entered at times.
• Officer statements: multiple reminders that he did not have to speak; no threats or promises; no communicated plan to arrest.
• Duration: roughly 35 minutes before Miranda warnings were administered once probable cause arose.

Against that backdrop, a reasonable person would have felt free to end the interview and leave the room. That is dispositive for Miranda. The Court addressed two defense arguments:

• Involuntary mental-health hold (10-13). Even assuming a 10-13 was in effect, it does not automatically create Miranda custody. Howes v. Fields teaches that being “in custody” for other legal reasons (e.g., imprisonment or civil commitment) does not convert every interview into Miranda custody; the question remains whether a reasonable person would feel free to end the questioning and leave the interview context. Georgia’s hospital-interview cases—Jennings and Robinson—support that conclusion, and the Court treated a behavioral health facility similarly.
• Officers’ suspicion/focus of investigation. The detectives’ subjective belief that Gravitt was a suspect, or even a plan to arrest him, did not matter absent communication of that intent to the suspect. Stansbury and Murphy squarely foreclose using unarticulated suspicion or the mere “focus” of an investigation to bootstrap noncustodial encounters into Miranda custody.

Notably, the Court observed that Gravitt did not raise a separate due process voluntariness challenge based on mental illness (compare Blackburn v. Alabama, 361 U.S. 199 (1960)), and thus confined its analysis to Miranda custody.

2) Insanity—Delusional Compulsion Instruction

The defense sought to modify the pattern delusional compulsion instruction by striking the “if true, would have justified the act” language and substituting phrasing from Lawrence. Counsel’s theory was that Gravitt’s delusion—that the victim was a non-human “draco”—meant that, if the facts were as he believed, killing would not constitute “murder” because murder requires the death of a human being (OCGA § 16-5-1).

The Supreme Court relied on Lawrence itself to hold the pattern instruction correctly states the law: a delusion excuses only if the imagined facts, if true, would render the act lawful. That requirement keeps the delusional compulsion defense tethered to objective legal justification, rather than excusing because the act was compelled by delusion alone. Because the trial court used the pattern instruction—which already incorporates Lawrence—the requested modification added no essential legal point and could be refused under Eubanks.

3) Insanity—“Utterly Senseless and Abnormal” (Brown) Charge

The defense requested a Brown v. State charge: “the act itself may be so utterly senseless and abnormal as to furnish satisfactory proof of a diseased mind.” The Court explained Brown is distinguishable because no insanity charge was given there, whereas here the jury received the pattern insanity instructions. Bennett confirms that when an insanity instruction is given and is sufficient, the court may properly refuse the Brown language, which risks redundancy or undue emphasis.

4) Voluntary Intoxication Instructions

The trial court delivered pattern instructions reflecting Georgia law that voluntary intoxication is generally no defense, except where intoxication has produced a more-than-temporary alteration in brain function that negates intent. During the charge conference, the court added the word “continuous” to one pattern instruction—an edit not challenged on appeal—and declined two additional non-pattern charges the defense proposed:

• A modernized articulation of Choice v. State (1860) asserting a person insane when sober remains insane when intoxicated.
• A two-part instruction distinguishing immediate, temporary intoxication (no defense) from permanent, fixed insanity caused by prolonged intoxication (potential defense if it meets the insanity standard).

The Supreme Court held the pattern charges, together with the insanity instructions, adequately and accurately covered the governing principles:

• A defendant who is insane when sober does not lose the insanity defense merely because he was also intoxicated at the time; the jury was instructed that a voluntarily intoxicated person is responsible “to the same extent as if the person were sober,” which necessarily preserves any independent insanity defense.
• Only a more-than-temporary alteration of brain function from intoxication can negate intent (Guyes; Scott; Hayes (1993)). The pattern instructions conveyed this; additional non-pattern verbiage would have been cumulative.

Because the requested non-pattern charges added no essential point beyond what the jury received, the refusals were not error.

Impact and Practical Implications

A. Miranda and Mental-Health Settings

Gravitt fortifies a practical, setting-sensitive approach to Miranda custody in medical and mental-health environments:

• No per se rule: A civil mental-health hold (10-13) does not automatically render a police interview “custodial.” The focus remains on the interview conditions—restraint, isolation, duration, advisements, and whether officers communicated an intent to arrest.
• Alignment with hospital cases: By treating a behavioral health facility similarly to hospitals (Jennings, Robinson, Whittaker), the Court offers a coherent framework across medical contexts.
• Law enforcement guidance: Officers should maintain noncustodial hallmarks if they wish to interview without Miranda—no restraints, clear statements that the person need not speak, permit staff access, keep the encounter brief, and avoid communicating arrest decisions. Once probable cause crystallizes, Miranda must be administered before further interrogation.
• Defense strategy: Counsel should distinguish Miranda custody from voluntariness. Where mental illness is significant, a due process involuntariness challenge (e.g., Blackburn) may be viable even if the interview is noncustodial for Miranda purposes.

B. Insanity Instructions—Delusional Compulsion

The opinion reinforces that the pattern delusional compulsion instruction is anchored in longstanding Georgia law (and Lawrence) and is ordinarily sufficient. Defense attempts to rephrase the standard—especially to avoid the “if true, would have justified the act” requirement—will generally fail unless the case presents a truly novel legal nuance not adequately captured by the pattern.

Practically, defendants relying on delusional compulsion must marshal evidence that the imagined facts, taken as true, would have made their act lawful (e.g., a justifying circumstance under Georgia law) and that the delusion overmastered their will (OCGA § 16-3-3). Mere compulsion by delusion, absent legal justification if the facts were true, will not suffice.

C. Voluntary Intoxication

The Court underscores that Georgia’s pattern instructions already capture the nuanced carve-out for intoxication-induced incapacity: only a more-than-temporary alteration in brain function that negates intent can excuse, and the defendant bears the burden when asserting insanity. A person insane when sober retains the insanity defense notwithstanding intoxication; separate, cumulative instructions are generally unnecessary.

Note: The opinion observes that certain pattern instructions were revised in July 2024. Trial courts should consult the latest versions. Although this case did not turn on the trial court’s addition of “continuous,” courts should be cautious when modifying patterns; the established “more-than-temporary” phrasing from Guyes/Scott/Hayes remains the touchstone.

Complex Concepts Simplified

• Miranda custody: Miranda warnings are required only when a suspect is both (a) interrogated and (b) “in custody,” meaning formally arrested or under restraints equivalent to formal arrest. The test is objective: would a reasonable person feel free to end the questioning and leave? The location (hospital, jail, mental-health facility) is informative but not determinative; what matters are the conditions of the interview.
• “10-13” (Form 1013): A Georgia mental-health form used to initiate involuntary evaluation when a person poses a substantial risk of imminent harm to self or others. Being under a 10-13 is separate from criminal custody. It does not automatically create Miranda custody, though it may bear on whether a reasonable person would feel free to terminate a police interview within the facility.
• Insanity defenses in Georgia:
  • Right–wrong test (OCGA § 16-3-2): The defendant could not distinguish right from wrong regarding the act at the time.
  • Delusional compulsion (OCGA § 16-3-3): Because of mental disease, the defendant acted under a delusion that overmastered the will; the delusion must be as to facts that, if true, would justify the act.
• Guilty but mentally ill (GBMI): A verdict acknowledging mental illness at the time of the offense but finding the defendant criminally responsible. It results in a criminal sentence, with statutory provisions for mental health treatment during incarceration.
• Voluntary intoxication: Not a defense in Georgia unless the intoxication produced a more-than-temporary alteration of brain function that negated the required mental state. Temporary drunkenness or drug-induced psychosis typically does not excuse criminal conduct unless it rises to the level of permanent (or more-than-temporary) impairment of intent-forming capacity.
• Standards of review:
  • Suppression (Miranda custody): Courts apply de novo review to legal principles and accept the trial court’s factual findings (even implicit ones) unless clearly erroneous.
  • Jury instructions: The charge is reviewed as a whole; refusal to give a requested instruction is not error if the substance is substantially covered by the instructions given. Properly preserved claims are reviewed de novo.

Key Takeaways

• No per se Miranda custody for interviews conducted at behavioral health facilities, including where an involuntary mental-health hold is in place; the usual objective custody analysis applies.
• Officers’ uncommunicated suspicions or intentions to arrest do not create custody; clear communication that the interviewee need not speak, absence of restraint, presence of staff, and limited duration militate against custody.
• Georgia’s pattern instructions on delusional compulsion and on voluntary intoxication remain controlling and sufficient absent a genuine gap; trial courts may properly refuse cumulative or reworded non-pattern charges.
• For delusional compulsion, the “if true, would have justified the act” element is essential and limits the defense to delusions that map onto objective legal justification.
• Voluntary intoxication is not a defense unless it causes a more-than-temporary alteration in brain function that negates intent; intoxication does not strip a defendant of an otherwise viable insanity defense.

Conclusion

Gravitt v. State offers a clear, practical reaffirmation of Miranda custody principles in mental-health settings, rejecting a categorical rule that would treat civil mental-health holds as custodial per se. By analogizing behavioral health interviews to hospital interviews and adhering to the objective, totality-based inquiry, the decision provides workable guidance to law enforcement and trial courts alike.

On the substantive criminal law side, the Court’s fidelity to Georgia’s pattern instructions solidifies two important doctrinal points. First, delusional compulsion remains bounded by the requirement that the imagined facts, if true, would justify the act—an anchor against an overly broad, purely subjective conception of legal excuse. Second, voluntary intoxication is almost never a defense; only a more-than-temporary brain-function alteration negating intent can excuse. Together, these rulings ensure consistent charging practices and forestall confusion when insanity and intoxication issues intersect.

The opinion’s enduring value lies in its synthesis of longstanding Miranda and insanity jurisprudence with the realities of mental-health interventions. It equips practitioners with a dependable framework for assessing interviews in clinical environments and for crafting, litigating, and instructing on insanity and intoxication defenses in Georgia courts.