Mata, Ricardo
PD-0810-19
Tex. Crim. App.Jun 23, 2021Background:
- A 15‑year‑old girl was kidnapped; appellee (Ricardo Mata) called the victim’s mother and demanded ransom.
- Investigators traced Mata’s phone, stopped his vehicle, and questioned him roadside without giving Miranda warnings.
- Investigators accused Mata of the kidnapping; after aggressive questioning and being told he would not be free to leave, Mata said he would disclose the child’s location in exchange for release and then revealed where she was.
- The trial court suppressed the roadside statements, finding Mata was in custody and Miranda warnings were not given.
- The court of appeals affirmed suppression, viewing the public‑safety exception as narrow and typically weapon‑related; the State petitioned for discretionary review.
- The Texas Court of Criminal Appeals reversed the court of appeals, holding the public‑safety exception applies to attempts to locate a kidnapped child and that the roadside statements were admissible.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miranda warnings were required before asking the location of the kidnapped child while Mata was in custody | Public safety exception applies; immediate answers necessary to protect child | Miranda required; officers failed to warn; statements should be suppressed | Court: Miranda not required; public‑safety exception applies; roadside statements admissible |
| Whether the public‑safety exception is limited to weapon cases | Exception should cover any immediate threat to public safety, including kidnapped children | Exception is narrow and traditionally applied to weapons, so it does not apply here | Court: Exception not limited to weapons; Quarles rationale extends to child rescue |
Key Cases Cited
- New York v. Quarles, 467 U.S. 649 (1984) (established the public‑safety exception to Miranda when immediate questions are reasonably prompted by concern for public safety)
- Black v. State, 26 S.W.3d 895 (Tex. Crim. App. 2000) (recognizing the State’s compelling interest in protecting children)
- Henderson v. State, 962 S.W.2d 544 (Tex. Crim. App. 1997) (permitting intrusion on certain privileges to pursue rescue of a kidnapped child)
- People v. Davis, 46 Cal.4th 539 (2009) (California’s “rescue” doctrine admits statements taken without Miranda when there was a reasonable possibility of rescuing a live kidnapping victim)