Edward Leron Satchell v. State, 05-14-01197-CR

Edward Leron Satchell was arrested for an alleged home-invasion aggravated robbery and later interrogated by Detective I.C. Hale; he confessed both orally and in writing.
Two videos exist: one of the Miranda admonition at the arrest scene in the patrol car and a second of the formal interrogation at the police station where a Miranda form was shown and signed.
At the scene Hale read Miranda-like warnings; Satchell said he understood and sought to speak; Hale told him they would talk at the station.
At the station (less than one hour later) Hale again began to read the warnings, Satchell said he "understand[ed] everything," declined a lawyer, signed the Miranda form and then gave oral and written statements.
Defense moved to suppress on voluntariness/Miranda grounds; trial court reviewed the videos, denied suppression, and later entered written findings required by art. 38.22 §6 after remand from this Court.
The trial court admitted the interrogation video at trial; a jury convicted Satchell of aggravated robbery and he was sentenced to 45 years. The Court of Appeals affirmed.

Issue	Satchell's Argument	State's Argument	Held
Whether Satchell knowingly, intelligently, and voluntarily waived Miranda/art. 38.22 rights	Warnings at station were ineffective because Satchell did not actually read the form while signing and thus did not understand the rights	Warnings at the scene and station substantially complied; signing and verbal statements show understanding and waiver	Waiver was valid; statements admissible — interrogation at station was effectively a continuation of the earlier admonition
Whether trial court erred by failing to enter written findings of fact and conclusions under art. 38.22 §6	Trial court initially lacked written findings, violating statute	Court later entered findings after abatement	Moot — remand complied; written findings were entered and satisfy art. 38.22 §6

Urias v. State, 155 S.W.3d 141 (Tex. Crim. App. 2005) (trial courts must issue written findings and conclusions under art. 38.22 §6)
St. George v. State, 237 S.W.3d 720 (Tex. Crim. App. 2007) (bifurcated review of suppression rulings: defer to historical facts, de novo legal review)
Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (trial court as factfinder; appellate review limited on credibility and weight)
Oursbourn v. State, 259 S.W.3d 159 (Tex. Crim. App. 2008) (various bases for involuntariness; constitutional involuntariness implies statutory involuntariness)
Bible v. State, 162 S.W.3d 234 (Tex. Crim. App. 2005) (substantial compliance with art. 38.22/Miranda is sufficient)
Dunn v. State, 721 S.W.2d 325 (Tex. Crim. App. 1986) (rewarning not required where later questioning is merely a continuation of earlier interrogation)
Griffin v. State, 765 S.W.2d 422 (Tex. Crim. App. 1989) (proper warnings and an express waiver generally suffice to meet State's burden on voluntariness)