Roberto Savedra v. State, 13-15-00089-CR

Trooper Rios stopped Roberto Savedra (and passenger wife Olga) for vehicle defects; during the encounter both appeared unusually nervous and gave inconsistent travel explanations.
Within 3–4 minutes of the stop, Rios requested and Savedra consented to a vehicle search; Rios observed signs of tampering with the driveshaft and asked Savedra to follow him to a nearby garage for further inspection.
At the garage Rios again obtained consent, drilled an inspection hole in the driveshaft, and ultimately dismantled it to discover 9.60 pounds of marijuana.
Sgt. Pat Brennan later read Miranda warnings, Savedra waived rights on a recorded 25‑minute interview in English, and Savedra admitted possession.
Savedra was arrested (case initially from 1999; defendant returned to Jackson County in 2014), tried by bench, found guilty of possession (5–50 lb.), and sentenced to six years’ imprisonment.
The trial court denied motions to suppress; it found probable cause for the stop, that consent to searches was given, and that the custodial statement and waiver were voluntary and understood.

Issue	Savedra's Argument	State's Argument	Held
1. Whether detention was unlawfully prolonged	Stop completed; further questioning/consent came after an unlawful prolongation	Stop was to effectuate traffic stop and Rios had reasonable suspicion to continue	Denied — detention was lawful; at most 3–4 minutes and Rios had articulable suspicion to continue
2. Whether officer needed to Mirandize before requesting consent to search	Custodial escalation required Miranda before consent; search therefore invalid	No requirement to Mirandize before seeking consent; consent can be valid without warnings	Denied — no Miranda required prior to consent; consent need not follow Miranda
3. Whether consent to search was voluntary	Consent involuntary because defendant wasn’t aware he could refuse and language barrier existed	Consent was voluntary: brief stop, not handcuffed, drove to garage, gave written consent; communications in English	Denied — trial court credited voluntariness and English comprehension; consent valid
4. Whether custodial statement waiver was voluntary and knowing	Waiver involuntary because defendant had limited English and interviewer didn’t speak Spanish	Waiver was knowing: warnings given, interview recorded, trial court found defendant understood and waived	Denied — trial court’s factual findings supported that waiver and confession were voluntary

Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (standard of review for suppression rulings; deference to trial court’s fact findings)
Rodriguez v. United States, 135 S. Ct. 1609 (U.S. 2015) (duration of traffic stop limited to tasks of stop; subsequent detention requires reasonable suspicion)
Royer, 460 U.S. 491 (U.S. 1983) (traffic stop investigative limits)
Davis v. State, 947 S.W.2d 240 (Tex. Crim. App. 1997) (stop duration judged by diligence in dispelling suspicions)
Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (consent search exception to warrant requirement; voluntariness judged from all circumstances)
Rayford v. State, 125 S.W.3d 521 (Tex. Crim. App. 2003) (consent validity, burden and standards under Texas Constitution)
Johnson v. State, 68 S.W.3d 644 (Tex. Crim. App. 2002) (consent can be voluntary despite arrest or absence of Miranda when totality of circumstances support voluntariness)
Valtiera v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (objective-reasonableness test for consent)