Rodney Boyett v. State, 06-15-00024-CR

Background

Law enforcement monitored pseudoephedrine purchases and flagged Jessica Boyett after a CVS purchase; officers linked a white pickup to Rodney Boyett and conducted surveillance.
Officers observed the couple stop at Home Depot and Wal‑Mart, then traveled toward Oklahoma; during the drive an officer observed the pickup fail to maintain a single lane and initiated a traffic stop.
During the stop Rodney admitted purchases of pseudoephedrine and that “liquid heat” was in the vehicle; officers searched the vehicle and found pseudoephedrine/ephedrine, liquid heat, tubing, and hydrogen peroxide.
Rodney and Jessica were arrested for possession of chemicals; both were interviewed, given Miranda warnings, and Rodney made a recorded confession describing methamphetamine manufacture.
Rodney moved to suppress the stop, search, arrest, and his statement; the trial court denied the motion, he pleaded guilty pursuant to a plea agreement (Count 2 abandoned), received probated confinement and a fine, and reserved the right to appeal pretrial rulings.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Boyett)	Held
1. Validity of traffic stop (reasonable suspicion)	Stop justified: observed lane deviation in heavy traffic under Tex. Transp. Code §545.060; surveillance and pharmacy‑purchase investigation supported suspicion of a “pill run.”	Officer’s description insufficient to show unsafe lane movement; flagged purchase alone insufficient for reasonable suspicion.	Denial of suppression upheld: lane violation in heavy traffic + corroborating surveillance could support reasonable suspicion.
2. Lawfulness of warrantless arrest and search (probable cause)	Probable cause existed from surveillance, admissions during the stop, and visible indicia (admissions of purchases, items in vehicle) to search and arrest without a warrant.	Arrest/search were unlawful and tainted the confession because probable cause was lacking.	Denial of suppression upheld: objective facts available to officers supported a prudent person’s belief that an offense had occurred; warrantless arrest/search lawful.
3. Voluntariness and admissibility of recorded statement	Statement was voluntary, given after Miranda warnings; any contention of denial of counsel or threats was disbelieved by the court.	Statement involuntary: custodial interrogation without counsel, threats (loss of vehicle) coerced confession.	Denial of suppression upheld: trial court (credibility determinations) found Miranda warnings given, no credible threats or denial of counsel; statement admissible.
4. Sufficiency of evidence under Art. 1.15 (judicial confession)	Judicial confession in plea papers and open plea established guilt and satisfies article 1.15; conviction may be sustained on that basis.	(Implicit) Plea cannot be sustained because pretrial rulings should have excluded evidence and tainted plea.	Conviction sustained: judicial confession and plea colloquy provide sufficient evidence to support conviction.

Key Cases Cited

Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (probable cause test for warrantless arrest)
Romero v. State, 800 S.W.2d 539 (Tex. Crim. App. 1990) (deference to trial court credibility findings at suppression hearings)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (bifurcated standard of review for suppression rulings)
Martinez v. State, 348 S.W.3d 919 (Tex. Crim. App. 2011) (deference to trial court on voluntariness; standards for mixed questions)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (definition and requirements for custodial interrogation)
Thompson v. Keohane, 516 U.S. 99 (U.S. 1995) (custodial status as a mixed question of law and fact reviewed de novo)