Brandon Keione Williams v. State, 12-14-00274-CR

Deputy Johnny Gorden attempted a traffic stop for speeding and expired registration; the vehicle fled and later reached speeds over 135 mph before crashing into storage buildings.
Brandon Keione Williams exited the vehicle, ran, was pursued, caught, and arrested after a struggle.
Williams made statements to Deputy Gorden at the scene before receiving Miranda warnings, including asking why he was pulled over and volunteering that he had a warrant.
At trial Williams was convicted of evading arrest or detention with a vehicle and sentenced to seven years’ imprisonment; he appealed only the admissibility of his pre-Miranda statements.
The trial court held a hearing (voir dire) on admissibility; the court ruled the officer could testify to statements the defendant initiated but not to answers that were the product of the officer’s questioning.
The Court of Appeals affirmed, concluding the challenged statements were volunteered and not the product of custodial interrogation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams’s pre-Miranda statements were products of custodial interrogation and therefore inadmissible	Williams: His statements (including explanations for running and admitting a warrant) were responses to police questioning (e.g., “Why did you run?”) and should have been excluded as elicited by interrogation	State (via Gorden): The statements were volunteered or responses to defendant-initiated questions, not the result of officer interrogation; if officer asked any incriminating question, it occurred later at the jail	Court affirmed: testimony supported that statements were volunteered and not elicited by custodial interrogation, so admission was not an abuse of discretion

Martin v. State, 173 S.W.3d 463 (Tex. Crim. App. 2005) (standard of review for evidentiary rulings)
Willover v. State, 70 S.W.3d 841 (Tex. Crim. App. 2002) (uphold trial court ruling if supported by record or correct under any theory)
Burden v. State, 55 S.W.3d 608 (Tex. Crim. App. 2001) (will not reverse evidentiary ruling unless outside zone of reasonable disagreement)
Alford v. State, 358 S.W.3d 647 (Tex. Crim. App. 2012) (definition of interrogation includes express questioning and words/actions reasonably likely to elicit incriminating response)
Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (Miranda interrogation definition)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires warnings before admissible statements)