Howard Martin Harris v. State, 14-14-00392-CR

Complainant alleged appellant Howard Martin Harris beat her with a belt and fists, cut off her bra with a hunting knife, sexually assaulted her with finger penetration, and threatened she would be found in a ditch if she reported it.
The complainant escaped with a knife, left it, drove to a nearby sheriff’s office, and reported the assault; deputies observed her injuries and distraught state.
Deputies Hunt and Cooley relayed facts to Corporal Keele; officers believed they had probable cause for assault causing bodily injury and were concerned about risk of future harm to the complainant.
Officers went to appellant’s home, handcuffed him for investigative detention, obtained his consent to enter, read Miranda, and secured written consent to search; they did not find the alleged knife.
After consulting the assistant district attorney (who confirmed probable cause), officers arrested appellant without a warrant and videotaped an interview; the State used the videotape at trial.
Appellant moved to suppress the videotaped statement as fruit of an illegal warrantless arrest; the trial court denied suppression, appellant pled guilty, received concurrent 20-year sentences, and appealed the suppression ruling.

Issue	Harris’s Argument	State’s Argument	Held
Whether the warrantless arrest was illegal so the videotaped statement must be suppressed	Arrest was illegal because no warrant was obtained; thus statement is fruit of illegal arrest	Warrantless arrest was authorized because officers had probable cause for assault causing bodily injury and a danger of further harm to the victim	Court held arrest lawful under art. 14.03(a)(2) and exigent-circumstance reasoning; suppression denied

Reed v. State, 809 S.W.2d 940 (Tex. App.—Dallas 1991) (evidence obtained through illegal arrest is inadmissible)
McClatchy v. State, 758 S.W.2d 328 (Tex. App.—Houston [14th Dist.] 1988) (officers may arrest without warrant when facts support belief suspect might return to harm victim)
Wilson v. State, 621 S.W.2d 799 (Tex. Crim. App.) (warrantless arrests/searches are unreasonable absent an applicable exception)
Randolph v. State, 152 S.W.3d 764 (Tex. App.—Dallas 2004) (risk of future harm to victim can constitute exigent circumstance justifying warrantless arrest)
Douds v. State, 434 S.W.3d 842 (Tex. App.—Houston [14th Dist.] 2014) (standard of review for suppression rulings)
State v. Elias, 339 S.W.3d 667 (Tex. Crim. App. 2011) (deference to trial court findings on historical facts and credibility)
Estrada v. State, 154 S.W.3d 604 (Tex. Crim. App. 2005) (uphold trial court if ruling correct under any applicable theory)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required for custodial interrogation)