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