Dixon, William Michael
PD-1013-15
| Tex. App. | Aug 11, 2015Background
- Dixon was indicted June 7, 2013 in the 208th District Court of Liberty County for Driving While Intoxicated 3rd Offender.
- Trial occurred June 18–20, 2014; the jury found Dixon guilty and the court sentenced him to 40 years in the Texas Department of Criminal Justice.
- Dixon allegedly confessed to driving after questioning by Officer Martinez, without any Miranda or Article 38.22 warnings.
- Officers handcuffed Dixon and placed him in the back of a patrol car and transported him before taking him to a substation for field sobriety testing.
- The question presented includes whether Dixon was in custody for Miranda purposes during questioning and whether the evidence was legally sufficient to convict for DWI.
- The Texas Court of Criminal Appeals denied a motion for rehearing on the procedural posture presented in the petition for discretionary review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying suppression of the confession | Dixon argues he was in custody without warnings. | The State contends Dixon was not in custody for purposes of Miranda/Article 38.22. | Not stated in provided text. |
| Whether the evidence was legally sufficient to convict Dixon of DWI | There were credibility issues and possible non-driving conclusively shown by defense evidence. | Jury credibility and standard of review sustain the conviction. | Not stated in provided text. |
Key Cases Cited
- Balentine v. State, 71 S.W.3d 763 (Tex. Crim. App. 2002) (handcuffs alone do not prove custody; focus on restraint level)
- Rhodes v. State, 945 S.W.2d 115 (Tex. Crim. App. 1997) (custody assessment for Miranda purposes)
- Stansbury v. California, 511 U.S. 318 (U.S. Supreme Court 1994) (custody analysis for interrogation)
- Thompson v. Keohane, 516 U.S. 99 (U.S. Supreme Court 1995) (custody and interrogation standards in context)
- Dowthitt v. State, 931 S.W.2d 244 (Tex. Crim. App. 1996) (three of four Dowthitt factors indicating custody)
- Miranda v. Arizona, 384 U.S. 436 (U.S. Supreme Court 1966) (mandatory warning requirements for custodial interrogation)
- Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (juror credibility and weight given to evidence and witness testimony)
- Lancon v. State, 253 S.W.3d 699 (Tex. Crim. App. 2008) (credibility and standard of review for jury verdicts)
- Curry v. State, 30 S.W.3d 394 (Tex. Crim. App. 2000) (reliability and sufficiency considerations on appeal)