James Arthur Baxley v. State
06-15-00095-CR
| Tex. App. | Sep 9, 2015Background
- On Sept. 23, 2014, Sgt. Mark Estes (Sulphur Springs PD Special Crimes Unit) saw on a municipal court list that there were two outstanding warrants for James Baxley arising from traffic citations. Estes confirmed the warrants’ validity with dispatch but did not bring copies.
- Estes and another officer drove in an unmarked car to the house they believed was Baxley’s residence; Estes had prior encounters with Baxley.
- Estes observed Baxley kneeling by a car in the front yard, told him he was under arrest for outstanding warrants, and asked him to stand.
- As Baxley stood, he reached for his wallet; Estes handcuffed him, retrieved the wallet from Baxley’s back pocket, and found a baggie containing methamphetamine (less than one gram).
- At the suppression hearing Estes was the sole witness. Baxley argued the instruments were capias pro fine (not valid arrest warrants) and sought suppression of the drugs as fruit of an invalid arrest.
- The trial court found Estes had a good-faith basis to arrest; denied suppression. A jury convicted Baxley of possession of methamphetamine and the court sentenced him to two years’ confinement (judgment later modified to reflect that sentence).
Issues
| Issue | Baxley’s Argument | State’s Argument | Held |
|---|---|---|---|
| Validity of arrest / suppression of evidence | Arrest was based on capiases pro fine (not valid warrants); arrest unlawful so evidence must be suppressed | Officer reasonably relied on outstanding warrants and had good-faith basis to arrest | Denied — trial court credited officer’s testimony; arrest legally authorized in good faith |
| Preservation / appellate complaint about credibility | Trial court erred in crediting Estes’ testimony (challenges credibility) | Appellate complaint did not match trial objection; issue not preserved; even if preserved, trial court’s credibility finding is entitled to deference | Overruled — appellate point not preserved; deference to trial court’s credibility finding would sustain decision even if preserved |
Key Cases Cited
- State v. Ross, 32 S.W.3d 853 (Tex. Crim. App. 2000) (trial court as exclusive factfinder; defer to factual findings and credibility)
- Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (deference to trial court credibility and factual findings)
- Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (standards for appellate review of factual findings and credibility)
- Villarreal v. State, 935 S.W.2d 134 (Tex. Crim. App. 1996) (mixed questions of law and fact turning on credibility reviewed with deference)
- French v. State, 830 S.W.2d 607 (Tex. Crim. App. 1992) (appellate courts may modify judgments to make the record speak the truth)