Marcos Daniel Jimenez v. State, 01-15-00501-CR

On April 5, 2013, Angela Mendoza and Christopher Burnett were robbed at gunpoint; one robber drove off in Burnett’s Malibu and the other in Mendoza’s stolen green Chevy Avalanche. A shell casing was recovered.
Officer D. Heckard stopped the Avalanche April 7; driver Andrew Madria was arrested. Madria implicated others and identified a Hispanic male who matched the complainants’ description.
Detective Sabrina Sanders reviewed EconoLodge video showing a Hispanic male and Latrice Beck, obtained the room registration listing Marcos Daniel Jimenez, and arranged to speak with Jimenez at the police station.
At the station Jimenez signed a Miranda waiver and gave a recorded statement implicating himself; he was later arrested and indicted for two counts of aggravated robbery (each with a prior felony enhancement).
Jimenez moved to suppress the statement as involuntary; the trial court denied the motion, the jury heard the statement (with a voluntariness instruction), convicted Jimenez, and assessed 25 years’ imprisonment on each count to run concurrently.
On appeal the court abated for the trial court to enter written findings of fact and conclusions of law about voluntariness; the trial court did so and the Court of Appeals affirmed the convictions.

Issue	Plaintiff's Argument (Jimenez)	Defendant's Argument (State)	Held
1. Legal sufficiency of evidence	Without the confession, evidence is only a vague physical description and is insufficient to support aggravated robbery convictions.	Consider all evidence (including the confession) and circumstantial evidence (matching descriptions, Madria’s identification, connection to stolen vehicle) is sufficient for a rational jury.	Affirmed: Viewing all evidence in favor of the verdict, a rational jury could find guilt beyond a reasonable doubt.
2. Adequacy of trial court’s post‑verdict findings	Abating the appeal and allowing post‑verdict written findings violates due process and Jackson v. Denno; findings from a “cold” record are unreliable.	Texas law permits abatement for written findings; same trial judge made original ruling so record isn’t “cold”; procedure satisfied Jackson/Denno.	Affirmed: Abatement and written findings by the same trial judge were proper and did not violate due process.
3. Denial of motion to suppress (voluntariness)	Statement was involuntary (claims of threats, coercion, and recent drug overdose/medication).	Trial court found waiver, voluntariness, absence of custody/threats; court may credit the officer and the videotaped statement; totality of circumstances supports voluntariness.	Affirmed: Trial court did not abuse discretion; findings legally sufficient and videotape properly considered and admitted.

Jackson v. Virginia, 443 U.S. 307 (legal‑sufficiency standard for convictions)
Jackson v. Denno, 378 U.S. 368 (requirement for fair hearing on voluntariness of confessions)
Hooper v. State, 214 S.W.3d 9 (circumstantial evidence probative as direct evidence)
Moff v. State, 131 S.W.3d 485 (appellate review considers all evidence admitted, even if erroneously)
Vasquez v. State, 411 S.W.3d 918 (trial courts must enter written findings on voluntariness)
State v. Cullen, 195 S.W.3d 696 (abatement doctrine for appellate review when findings are missing)
McKittrick v. State, 535 S.W.2d 873 (requirement to abate for written findings on voluntariness)
Guzman v. State, 955 S.W.2d 85 (bifurcated standard of review for suppression rulings)
Creager v. State, 952 S.W.2d 852 (totality of circumstances governs voluntariness)
Leza v. State, 351 S.W.3d 344 (trial judge may view videotaped confession to assess voluntariness)