Curtis Woodruff v. State
07-14-00339-CR
| Tex. App. | Jul 14, 2015Background
- Incident: Officer Sims responded to a 1:20 a.m. dispatch of a suspected vehicle burglary; he located appellant (Woodruff) matching the description carrying a black bag and briefcase.
- Initial detention: Sims activated lights, had Woodruff put items down, and conducted a frisk with hands on the patrol car hood. Woodruff was not free to leave (investigative detention).
- Pocket search: With verbal consent Sims searched pockets and found two debit cards bearing other people’s names; Woodruff gave inconsistent explanations.
- Handcuffs and further search: Sims handcuffed Woodruff (for officer safety/detention) and placed him in the patrol car, then obtained verbal consent to search the bag and case; the search produced a checkbook in victims’ names and other items.
- Miranda and arrest: Sims Mirandized Woodruff after locating the checkbook; Woodruff waived and made statements; after unsuccessful attempts to locate victims Woodruff was arrested.
- Procedural posture: Woodruff moved to suppress pre‑Miranda statements and physical evidence; trial court allowed pre‑Miranda investigative statements and consent searches but excluded statements given after Miranda warnings were not at issue; appellant appealed claiming Miranda violation and insufficient evidence.
Issues
| Issue | Plaintiff's Argument (Woodruff) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether appellant was "in custody" for Miranda when he made the pre‑Miranda statements | He was effectively in custody from the moment he was ordered to place hands on the patrol car and later handcuffed, so Miranda warnings were required | The encounter remained an investigatory Terry detention; restrictions (pat‑down, handcuffs, placement in patrol car) did not equal custody until after the bag was searched and the checkbook found | Trial court: detention was investigatory, not custodial, for the pre‑Miranda statements; statements before Miranda admissible |
| Whether asking for consent to search while handcuffed constituted "interrogation" under Miranda | Consent was obtained while effectively in custody and was prompted by the officer, so it should be suppressed as elicited without warnings | Requesting consent is not interrogation because consent is non‑testimonial and not reasonably likely to elicit incriminating responses | Held: request for consent was not interrogation; consent admissible |
| Whether physical evidence (checkbook, items from bag) must be suppressed as fruits of an unwarned custodial interrogation | If statements were involuntary/unwarned and led to the bag search, physical fruits must be excluded | Even if some statements were unwarned, Patane and Texas precedent permit admission of nontestimonial physical fruits; consent to search was voluntary | Held: physical evidence admissible; Miranda violation (if any) does not require suppression of non‑testimonial fruits |
| Whether the evidence was legally sufficient to support conviction for fraudulent use/possession of identifying info | Without improperly admitted testimony/evidence, insufficient proof links appellant to victims’ property or intent to defraud | Sufficiency review considers all admitted evidence (even improperly admitted); physical possession of the victim’s checkbook plus circumstances supports intent and lack of consent | Held: Evidence (including the checkbook possession) was legally sufficient to support conviction |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires procedural warnings)
- Thompson v. Keohane, 516 U.S. 99 (U.S. 1995) (custody determination objective test)
- Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (definition of "interrogation" for Miranda)
- Oregon v. Mathiason, 429 U.S. 492 (U.S. 1977) (Miranda limited to custodial situations)
- Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (two‑step question‑first warning‑later Miranda analysis)
- U.S. v. Patane, 542 U.S. 630 (U.S. 2004) (nontestimonial physical evidence need not be suppressed for Miranda violation)
- Dowthitt v. State, 931 S.W.2d 244 (Tex. Crim. App. 1996) (factors constituting custody for Miranda)
- Herrera v. State, 241 S.W.3d 520 (Tex. Crim. App. 2007) (custody test and appellate review of suppression rulings)
- Jones v. State, 119 S.W.3d 766 (Tex. Crim. App. 2003) (Miranda and admissibility of physical fruits)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for legal sufficiency review)