Curtis Ell White v. State, 14-13-00767-CR

Appellant Curtis Ell White was convicted by a jury of aggravated robbery and sentenced to 25 years' imprisonment.
Facts: White entered the complainant’s home with masked, armed accomplices, demanded money and access to a safe; the complainant feared for her life.
White does not dispute those facts but claims his intent was to collect a debt owed to him (i.e., to recover property), not to commit robbery.
White moved to suppress statements he made during a custodial interrogation, arguing the statements were involuntary because he was intoxicated from narcotics when he waived Miranda rights and spoke to police.
At the suppression hearing, the officer testified White showed no signs of intoxication; the recorded interrogation was admitted and the trial court found the officer credible, found White not credible, and concluded White was not intoxicated and knowingly and voluntarily waived his rights.
The court of appeals reviewed sufficiency and the suppression ruling and affirmed the trial court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for aggravated robbery	State: facts (masked, armed entry, demand for money, victim feared death) support robbery conviction	White: intended only to collect a debt from a relative of the complainant, not to rob the complainant	Affirmed: creditor status does not permit use of force; evidence legally sufficient for aggravated robbery
Suppression — voluntariness of statements due to intoxication	State: interrogation video and officer testimony show White was lucid and waived rights voluntarily	White: was under influence of many narcotic pills at time of interrogation, so waiver/statements were involuntary	Affirmed: trial court’s credibility findings supported; recording did not show intoxication; waiver voluntary

Crawford v. State, 509 S.W.2d 582 (Tex. Crim. App. 1974) (creditor cannot use force to collect a debt; such force may constitute robbery)
Collins v. State, 800 S.W.2d 267 (Tex. App.—Houston [14th Dist.] 1990) (debt collection by force can support aggravated robbery conviction)
Pierce v. State, 218 S.W.3d 211 (Tex. App.—Texarkana 2007) (creditor who uses force to collect a debt may commit aggravated robbery)
Armstrong v. State, 179 S.W.3d 84 (Tex. App.—Fort Worth 2005) (evidence supported robbery where defendant used a weapon while collecting a debt)
Oursbourn v. State, 259 S.W.3d 159 (Tex. Crim. App. 2008) (voluntariness inquiry focuses on whether statement was freely and voluntarily made; intoxication is a factor but not dispositive)
Paolilla v. State, 342 S.W.3d 783 (Tex. App.—Houston [14th Dist.] 2011) (totality of circumstances governs voluntariness; intoxication relevant only if it prevented informed, independent decision)
Jones v. State, 944 S.W.2d 642 (Tex. Crim. App. 1996) (when defendant used mind-altering agents, court examines whether those agents prevented an informed decision)