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Rodney Boyett v. State
06-15-00024-CR
Tex. Crim. App.
Sep 8, 2015
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Background

  • Rodney Boyett and his wife Jessica were investigated for "pill runs" after computerized pharmacy reports showed multiple pseudoephedrine purchases tied to the same address; officers followed the couple after they shopped at CVS, Home Depot, and Walmart.
  • Officer Foreman stopped Boyett’s vehicle after observing what he described as the driver’s tires cross the center line on a multi-lane roadway; Foreman then questioned the occupants about pseudoephedrine purchases.
  • During the stop Foreman searched the vehicle without a warrant and seized pseudoephedrine tablets, bottles of liquid HEET, tubing, and hydrogen peroxide; Boyett and Jessica were arrested for possession of certain chemicals.
  • At the station Jessica made statements implicating both in meth production; Boyett later gave a recorded statement admitting meth use and describing manufacture using red-phosphorous methods.
  • Boyett filed a motion to suppress; the trial court denied it the morning jury trial was to begin. Under a plea agreement Boyett pleaded guilty to conspiracy to manufacture methamphetamine (1–4 g) and received a five-year sentence probated for three years plus a fine. Boyett appealed, challenging the stop, the warrantless search and arrest, voluntariness of statements, and sufficiency of his judicial confession.

Issues

Issue Appellant's Argument (Boyett) State's Argument Held (trial court)
Legality of the traffic stop Stop was pretextual and Foreman lacked reasonable suspicion to detain for drug investigation Stop justified by observed lane-crossing violation under Tex. Transp. Code §545.060 Stop was valid; motion to suppress denied
Lawfulness of warrantless vehicle search and arrest No probable cause to search; items were "mere evidence" and arrest lacked statutory thresholds Statements and observed items provided probable cause for search and arrest Search and arrest upheld by trial court
Admissibility/voluntariness of Boyett’s recorded statement Statement was custodial, tainted by illegal arrest, given after coercion (threat re: vehicle) and denial of counsel Statement was voluntary; no coercion or improper promises Statement admitted; suppression denied
Sufficiency of judicial confession supporting guilty plea Confession failed to establish conspiracy elements required by Art. 1.15 (overt act in furtherance of agreement) Judicial confession and attendant facts satisfy Article 1.15 and support plea Trial court accepted the judicial confession and the guilty plea

Key Cases Cited

  • Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (framework for investigative detentions and reasonable-suspicion standard)
  • United States v. Mendenhall, 446 U.S. 544 (U.S. 1980) (totality-of-circumstances test for when a consensual encounter becomes a seizure)
  • Whren v. United States, 517 U.S. 806 (U.S. 1996) (objective legitimacy of traffic stops regardless of officer’s subjective intent)
  • Wade v. State, 422 S.W.3d 661 (Tex. Crim. App. 2013) (classification of police–citizen contacts and review standards)
  • Le v. State, 463 S.W.3d 872 (Tex. Crim. App. 2015) (probable-cause and voluntariness principles for confessions)
Read the full case

Case Details

Case Name: Rodney Boyett v. State
Court Name: Court of Criminal Appeals of Texas
Date Published: Sep 8, 2015
Docket Number: 06-15-00024-CR
Court Abbreviation: Tex. Crim. App.