Karl Patrick Houlditch v. State, 06-14-00207-CR

Appellant Karl Patrick Houlditch was charged with 30 counts of possession of child pornography and sentenced to eight years on each count, running consecutively after an open plea.
Motion to Suppress challenged the May 14, 2013 search warrant and its execution as stale/unreliable and inadequately supported by probable cause.
Detective Brownlee, a Longview Police Department (state) employee, coordinated with federal agents; the court treated the matter as a state-law suppression issue, not a purely federal one.
The State's subpoena and IP-address-based evidence connected to a 3368 Rupe Huffman Road address formed the core basis for the warrant affidavit, with substantial reliance on Brownlee’s local investigative work.
At trial, Appellant pled guilty to all counts, with the court accepting a guilty plea subject to resolution of the suppression issue; evidence included a judicial confession and images on a flash drive.
Appellant later challenged the 240-year cumulative sentence as cruel and unusual under the Eighth Amendment and Texas Constitution, arguing disproportionate punishment compared to federal analogs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the suppression ruling was erroneous due to stale evidence	Houltitch contends affidavit lacked timely probable cause.	State argues adequate linkage and protracted activity supported probable cause.	Trial court abused discretion; suppression reversed.
Whether state agents’ involvement negates federal ‘silver platter’ principles	State should govern; Brownlee’s state role invalidates federal-style reception of evidence.	Evidence admissible under federal-state mutual conduct; no true silver platter problem.	Silver platter/reverse doctrine does not apply; state law governs and remains problematic.
Whether Appellant’s May 22, 2013 statements should have been suppressed for Miranda custodial interrogation concerns	Statements obtained during custodial setting must be suppressed; no warnings given.	Appellant was not in custody; interview was voluntary.	Statements should have been suppressed; custodial interrogation occurred.
Whether the thirty consecutive eight-year sentences violate the Eighth Amendment and Texas Constitution	Cumulative 240-year sentence grossly disproportionate to the offense.	Discretionary punishment within statutory bounds and federal analogs.	Sentence deemed grossly disproportionate; remand on sentencing.

Reynolds v. State, 430 S.W.3d 467 (Tex. App. – San Antonio 2014) (disproportionate punishment comparison informs Eighth Amendment analysis)
Toone, 823 S.W.2d 744 (Tex. App. – Dallas 1992) (silver platter/agency-color analysis in mixed federal-state investigations)
Mollica, State v. Mollica, 114 N.J. 329, 554 A.2d 1315 (N.J. 1989) (interagency cooperation affects state vs. federal authority boundaries)
Lockett v. State, 879 S.W.2d 184 (Tex. App. – Houston [1st Dist.] 1994) (timeliness of facts tied to probable cause must be closely related to warrant issuance)
Ellis v. State, 722 S.W.2d 192 (Tex. App. – Dallas 1986) (guides staleness analysis in probable cause affidavits)