State of Texas v. Mazuca, Alvaro
2012 Tex. Crim. App. LEXIS 697
| Tex. Crim. App. | 2012Background
- Appellee Mazuca was charged with possession with intent to deliver 4–400 grams of methylenedioxymethamphetamine (ecstasy).
- Mazuca moved to suppress evidence from his initial detention, arguing the stop was illegal.
- El Paso police detained a yellow Mustang for a taillight infraction; Mazuca was a passenger when stopped around 10:20 p.m. near Sunland Park Mall.
- After identifying Mazuca, officers checked for outstanding warrants and discovered active warrants; Mazuca was then placed under arrest.
- A pat-down led to seizure of ecstasy and marijuana; Mazuca disclosed additional baggies of marijuana found under the seat.
- The trial court suppressed the evidence, finding the stop illegal and doubt about taillights; the court of appeals affirmed, concluding warrant discovery did not attenuate taint.
- The Texas Court of Criminal Appeals reversed, adopting attenuation analysis and holding that the arrest warrants between the stop and seizure could purge the taint under the Brown factors, focusing on purposefulness and flagrancy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the initial detention was an unlawful traffic stop | Mazuca | Mazuca | Stop unlawful; suppression required |
| Whether the discovery of Mazuca's warrants between stop and seizure attenuates taint | State | Mazuca | Warrants can attenuate taint under Brown factors |
| What Brown factors govern attenuation for physical evidence after an illegal stop | State | Mazuca | Purposefulness/flagrancy essential; intervening warrant not dispositive alone |
| Role of Miranda warnings in attenuation analysis where no confession is involved | State | Mazuca | Miranda warnings not controlling; focus on attenuation factors |
Key Cases Cited
- Wong Sun v. United States, 371 U.S. 471 (Supreme Court 1963) (attenuation of taint as a last resort; not all evidence tainted by illegality)
- Johnson v. State, 871 S.W.2d 744 (Tex. Crim. App. 1994) (identification evidence may be purged by intervening events; not dependent solely on warrants)
- Brown v. Illinois, 422 U.S. 590 (Supreme Court 1975) (three Brown factors; purposefulness of misconduct critical for taint attenuation)
- Reed v. State, 809 S.W.2d 940 (Tex. App.--Dallas 1991) (intervening warrant between illegal detention and contraband discovery can attenuate taint)
- Fletcher v. State, 90 S.W.3d 419 (Tex. App.--Amarillo 2002) (addressed attenuation of taint in context of contraband following illegal stop)
- State v. Elias, 339 S.W.3d 667 (Tex. Crim. App. 2011) (noted attenuation issue post Johnson; adoption of Brown factors varies by context)
- State v. Hummons, 253 P.3d 275 (Ariz. 2011) (Arizona approach prioritizes purposefulness/flagrancy in attenuation of taint for physical evidence)
- Lopez-Valdez, 178 F.3d 282 (5th Cir. 1999) (pretext stop analysis; taillight defect pretext stop can be unlawful)