Nicholas Arthur Dozet v. State, 01-18-00097-CR

Appellant (Nicholas Arthur Dozet), a homeless person, was found inside a locked Angleton ISD baseball concession stand after hours; he had been seen there previously during an earlier break-in investigation.
On March 2, 2017, an ISD coach observed Dozet inside the closed concession stand and summoned uniformed ISD officers.
Dozet exited the building as officers and the coach entered; Officer Ronnie Falks intercepted and temporarily detained him without handcuffs or an immediate arrest.
Falks asked Dozet his name and why he was at the scene; no Miranda warnings were given.
At trial Dozet moved to suppress the officer’s testimony about Dozet’s reply (that he was sleeping there); the trial court overruled the motion.
Appellant was convicted by a jury of criminal trespass (lesser-included offense of burglary) and appealed, arguing the detention was custodial and Miranda warnings were required.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Dozet)	Held
Whether officers had reasonable suspicion to detain Dozet	Facts (late hour, closed/locked concession, prior break-in, matching description, rapid exit) provided specific, articulable facts supporting reasonable suspicion of trespass/burglary	Detention was functionally an arrest; officer had probable cause and thus Miranda should have applied	Court upheld detention as a lawful investigative stop based on reasonable suspicion
Whether questioning was custodial interrogation triggering Miranda	Officer’s questions were routine identity/investigative queries during a temporary detention, not custodial interrogation	Dozet was not free to leave, not told he could; officer’s belief in probable cause made it custodial	Court held the encounter was an investigative detention, not custody for Miranda purposes; suppression not required

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required only for custodial interrogation)
Terry v. Ohio, 392 U.S. 1 (1968) (investigative stops justified by reasonable suspicion)
Berkemer v. McCarty, 468 U.S. 420 (1984) (temporary detentions are generally not custodial for Miranda)
Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (standards for reviewing investigatory detentions and trial-court fact findings)
State v. Sheppard, 271 S.W.3d 281 (Tex. Crim. App. 2008) (factors distinguishing detention from arrest)
Koch v. State, 484 S.W.3d 482 (Tex. App.—Houston [1st Dist.] 2016) (temporary detention during investigation may not be custodial despite restraints)
Dowthitt v. State, 931 S.W.2d 244 (Tex. Crim. App. 1996) (custody tested by whether a reasonable person would feel free to leave)