State of Texas v. Saenz, Clint
2013 Tex. Crim. App. LEXIS 1507
| Tex. Crim. App. | 2013Background
- Around 2:00 a.m., officers responded to a disturbance at a Corpus Christi restaurant and located two intoxicated men in a running truck; Saenz was the driver.
- Officer Bintliff ordered Saenz to turn off the truck, removed him from the vehicle, smelled alcohol, observed bloodshot eyes and slurred speech, and placed Saenz unhandcuffed in the back of a patrol car while requesting a DWI specialist.
- Officer Sanders later questioned Saenz while Saenz remained unhandcuffed in the patrol car; Saenz admitted driving to the restaurant and drinking about six beers, refused a breath test, failed field-sobriety tests, and was arrested for DWI.
- At a suppression hearing Saenz moved to suppress the statements to Officer Sanders as custodial interrogation without Miranda warnings; the trial court granted the motion and made limited findings, concluding Saenz was under arrest when Sanders questioned him.
- The court of appeals affirmed, applying a deferential standard to the custody determination and finding the officer’s placement of Saenz in the patrol car (without telling him he was free to leave) manifested probable cause and thus custody.
- The Court of Criminal Appeals granted review, held the court of appeals erred in applying an almost‑total‑deference standard to the ultimate custody legal question and in failing to abate for more complete trial-court findings, and remanded for supplemental findings.
Issues
| Issue | State's Argument | Saenz's Argument | Held |
|---|---|---|---|
| Proper standard of appellate review for whether a suspect was "in custody" for Miranda purposes | Court of appeals should review the ultimate custody legal question de novo because the question does not turn on witness credibility or demeanor | Trial court’s factual findings control; custody is fact-specific and the court of appeals should defer | The appellate court must apply deferential review to historical facts but review de novo the ultimate legal custody determination; the court of appeals erred by not doing so |
| Adequacy of trial-court findings after a requested suppression ruling | Trial court’s findings were incomplete; appellate court should abate for supplemental findings because essential facts (e.g., what was said, duration in car) are missing | Trial court’s existing findings were sufficient to support suppression | Trial court’s findings were inadequate; remand/abatement for supplemental findings required |
| Whether officer’s silent placement of suspect in patrol car manifestly conveyed probable cause and thus created custody | Silent placement alone does not necessarily manifest probable cause to the suspect; custody requires totality of circumstances (duration, words, police control) | Placement in patrol car without telling suspect he was free to leave manifested arrest and supported suppression | Court did not resolve the ultimate custody merits; held that silent placement alone is insufficient basis without further factual findings and totality analysis |
Key Cases Cited
- Thompson v. Keohane, 516 U.S. 99 (appellate courts conduct factual review of circumstances and de novo review of the ultimate custody legal question)
- Miranda v. Arizona, 384 U.S. 436 (constitutional rule requiring warnings when a suspect is in custody and subject to interrogation)
- Dowthitt v. State, 931 S.W.2d 244 (Tex. Crim. App.) (enumerates situations that may constitute custody for Miranda)
- Ortiz v. State, 382 S.W.3d 367 (Tex. Crim. App.) (explains bifurcated review: deference to historical facts; de novo to legal custody issue)
- Elias v. State, 339 S.W.3d 667 (Tex. Crim. App.) (trial court must make essential findings on request; appellate courts should abate when findings are inadequate)