Mark Eugene Engle v. State, 06-14-00239-CR

Defendant Mark Eugene Engle was charged with manufacturing and delivering methamphetamine (4–200 g); after the trial court denied his motion to suppress evidence, he pleaded guilty and received life imprisonment. Appeal timely noted.
Officers obtained a search warrant based on an affidavit sworn by Felicia White; much of the affidavit relayed facts “said report states” from another officer (Petrea) and a Jane Doe sexual-assault complainant who could not give details. White claimed training/experience in sexual-assault investigations but admitted limited experience preparing warrants.
The affidavit also referenced communications with Holly Robinson of a crisis center but provided no detail showing Robinson’s basis for knowledge or reliability of Jane Doe’s statements.
At the suppression hearing White conceded she had no knowledge of Jane Doe’s credibility or history and little corroboration existed; defense argued the affidavit contained false or recklessly made statements under Franks v. Delaware.
Trial court found probable cause within the four corners of the affidavit and denied the motion to suppress; appellant contends the warrant was legally insufficient and that the affidavit was prepared with reckless disregard for the truth, so suppression and reversal are required.

Issue	Appellant's Argument	State's Argument	Held
Whether the trial court erred in denying motion to suppress for insufficient probable cause to issue search warrant	Affidavit lacked sufficient facts within its four corners to establish (1) a specific offense, (2) that described items were evidence of that offense, and (3) that the items were located at the place to be searched; relied on uncorroborated, unreliable hearsay and officer inexperience	Magistrate reasonably found probable cause; warrants are reviewed with deference and affidavit should be read in a common‑sense manner	Trial court denied the motion to suppress (appellant seeks reversal on appeal)
Whether Franks hearing is warranted due to alleged false statements/reckless disregard in the affidavit	White made statements with reckless disregard for truth (admitted lack of corroboration and ignorance of complainant’s credibility); false material was essential to probable cause, so suppression required	State would dispute that any false or recklessly made material was both proved and essential to probable cause	Trial court did not grant relief at suppression; appellant argues record supports a Franks claim and requests a hearing/reversal

Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances standard for probable cause in warrant affidavits)
Jones v. United States, 362 U.S. 257 (U.S. 1960) (magistrate must have substantial basis to conclude a search will uncover evidence)
Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (entitlement to hearing if defendant makes substantial preliminary showing that affidavit contained intentional or reckless falsehoods that were essential to probable cause)
Swearingen v. State, 143 S.W.3d 808 (Tex. Crim. App. 2004) (deferential review of magistrate’s decision to issue a warrant)
Rodriguez v. State, 232 S.W.3d 55 (Tex. Crim. App. 2007) (encouraging use of warrants; affidavits read in common-sense manner)
Harris v. State, 227 S.W.3d 83 (Tex. Crim. App. 2007) (Franks framework and remedy analysis)
Clay v. State, 240 S.W.3d 895 (Tex. Crim. App. 2007) (harmless-error factors for constitutional error review)
Coats v. State, 815 S.W.2d 715 (Tex. Crim. App. 1991) (informant reliability and corroboration considerations)