Jessica Boyett v. State
06-15-00023-CR
| Tex. Crim. App. | Dec 4, 2015Background
- Law enforcement flagged purchases of pseudoephedrine and learned Jessica Boyett had just bought pseudoephedrine at a CVS; a white pickup registered to her husband Rodney was identified and placed under surveillance.
- Officers observed the pickup make stops at Home Depot and Wal‑Mart and then followed it; while on a busy loop they observed the vehicle fail to maintain a single lane and initiated a traffic stop.
- During the stop Rodney admitted purchasing pseudoephedrine and having "liquid heat" in the vehicle; officers conducted a warrantless probable‑cause search and found pseudoephedrine tablets, liquid heat, tubing, and hydrogen peroxide.
- Both Jessica and Rodney were arrested; Jessica gave two recorded interviews after receiving Miranda warnings and later signed a judicial confession.
- Jessica pleaded guilty pursuant to a plea agreement (Count 2 abandoned), received probated sentence and a fine, and appealed the denial of her pretrial motion to suppress.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Legality of the traffic stop (reasonable suspicion) | Stop was unsupported: purchase flagging and officer observations did not establish reasonable suspicion or an unsafe lane movement | Stop lawful: officer observed failure to maintain single lane under heavy traffic and had corroborating "pill run" investigation from flagged pseudoephedrine purchases | Trial court could credit officer testimony; stop upheld as reasonable and lawful |
| 2. Legality of warrantless arrest and search; voluntariness/admissibility of statements | Arrest/search illegal for lack of probable cause; confession tainted and involuntary (requests for counsel, threats re: children) | Probable cause existed from surveillance, admissions, and officer knowledge; Miranda warnings given, defendant did not request counsel, and threats not proven — statements voluntary | Trial court’s factual findings supported probable cause, admissibility, and voluntariness; confession admitted |
| 3. Sufficiency of evidence to support conviction under Art. 1.15 (judicial confession) | Judicial confession insufficient | Judicial confession plus plea establishes guilt | A signed judicial confession and guilty plea suffice under Article 1.15; conviction sustained |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (defining custodial interrogation and Miranda warnings requirement)
- Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (probable cause test for warrantless arrest)
- State v. Kerwick, 393 S.W.3d 270 (Tex. Crim. App. 2013) (reasonable‑suspicion analysis can rest on combined facts even if each in isolation is weak)
- Blanks v. State, 968 S.W.2d 414 (Tex. App.--Texarkana 1998) (custodial statements admissible where warnings given and waiver shown)
- Dinnery v. State, 592 S.W.2d 343 (Tex. Crim. App. 1979) (judicial confession sufficient to support conviction under Article 1.15)