Lopez, Roel Alvarez, PD-1376-15

Lopez was interrogated over three days after arrest for murder.
The initial unrecorded interview occurred on the first day; waiver of Miranda rights was disputed.
The police later recorded two additional interviews and obtained a written confession.
The State sought to exclude statements derived from an allegedly unlawful interrogation under fruit-of-the-poisonous-tree principles.
The Thirteenth Court of Appeals affirmed, holding that coercion during the initial interview was not established and that fruits of a later statement could be admitted under Baker/Patane framework.
The Texas Court of Criminal Appeals granted discretionary review to address coercion and Edwards/38.23 issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Coercion in the first interview	Lopez argued coercion occurred in the initial interview.	State argued no coercion, and fruits doctrine limits apply only to later statements.	Issue rejected; suppression affirmed; no COERCIVE first-interview finding.
Edwards/38.23 exclusion for fruits	Edwards violation should trigger Article 38.23 exclusion of fruits.	Patane/Baker framework allows fruits from Miranda-Edwards violations to remain admissible.	Held not to extend Edwards exclusion to fruits; fruits admissible where no coercion established.
Right to counsel and interrogation cessation	Invoking right to counsel requires termination of interrogation and exclusion of tainted fruits.	Texas follows existing U.S. precedents permitting admission of tainted fruits in certain contexts.	Held that the invocation rule and its deterrence rationale do not mandate suppression of fruits here.
Overruling Baker/Pantane precedent	Baker should be reexamined; Pantane should control, extending exclusion.	Maintain Baker/Pantane framework or distinguish appropriately.	Held not to overrule Baker; court sustains the current approach and affirms lower court ruling.

Edwards v. Arizona, 451 U.S. 477 (1981) (right to counsel must stop interrogation when invoked)
Patane v. United States, 542 U.S. 630 (2004) (mere failure to warn does not trigger exclusion; Edwards Miranda-violation distinctions apply)
Baker v. State, 956 S.W.2d 19 (Tex. Crim. App. 1997) (fruits of a Miranda violation may be excluded; coercion standard discussed)
In re H.V., 252 S.W.3d 319 (Tex. 2008) (miranda issues in juvenile context; applicability to exclusionary rule)
Contreras v. State, 312 S.W.3d 566 (Tex. Crim. App. 2010) (coercion and due process considerations in confession)
Gilkerson v. United States, 431 F.Supp.2d 270 (N.D.N.Y. 2006) (exclusionary rule in Edwards/Miranda contexts discussed)
Maryland v. Shatzer, 559 U.S. 98 (2010) (tenuous influence on detention and interrogation rules)
Arizona v. Roberson, 486 U.S. 675 (1988) (Edwards lineage and right to counsel protections)