State v. Miesha Valrae Robinson
09-16-00090-CR
| Tex. App. | Nov 16, 2016Background
- Trooper stopped Miesha Valrae Robinson on a Liberty County highway after following her briefly for driving 5 mph over the limit; he initially intended to issue a warning.
- Trooper noted several subjective indicators (out-of-state plates, a very clean car, air freshener smell, shaking hands, key not on a keychain) in an area known for drug transport.
- While stating he would issue a warning, the trooper had Robinson exit her vehicle, continued questioning her, and ran computer checks showing no warrants and that the vehicle was not stolen.
- Approximately seven minutes into the stop the trooper asked for consent to search the car; Robinson immediately consented and the trooper later found cocaine in a hidden compartment.
- Robinson moved to suppress the evidence, arguing the stop was unduly prolonged and her consent was tainted because it occurred after the mission of the stop had ended; the trial court granted suppression.
- The State appealed; the Court of Appeals reviewed under the deferential standard for mixed fact-and-law issues and affirmed the trial court, holding the detention was unlawfully prolonged and consent was tainted.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Robinson) | Held |
|---|---|---|---|
| Whether trooper lawfully prolonged traffic stop to seek consent to search | Actions and indicators gave reasonable suspicion to extend detention and obtain consent | Stop was prolonged beyond mission (issuing a warning); subsequent consent was tainted by illegal detention | Court: Stop was unlawfully prolonged; consent occurred after mission ended and was tainted; suppression affirmed |
| Whether consent was voluntary and an exception to warrant requirement | Consent was immediate and voluntary, satisfying clear-and-convincing proof required | Consent followed an illegal detention and thus was not valid | Court: Even if facially voluntary, consent was the product of an unduly prolonged stop and invalid |
| Whether attenuation dissipated the taint of illegal detention | State: any taint dissipated by short time and computer checks | Robinson: no intervening circumstance; officer did not inform her she could refuse; consent was solicited, not volunteered | Court: Attenuation factors favored suppression (temporal proximity, no intervening circumstances, questionable flagrant purpose) |
| Whether trial court's suppression ruling abused discretion | State: trial court erred in crediting defendant’s position over officer’s reasonable suspicion | Robinson: trial court properly weighed credibility and law; suppression appropriate | Court: No abuse of discretion; trial court’s ruling reasonable under deferential review |
Key Cases Cited
- Amador v. State, 221 S.W.3d 666 (Tex. Crim. App. 2007) (State bears burden to prove warrantless search reasonable at suppression hearing)
- Terry v. Ohio, 392 U.S. 1 (1968) (investigative stop standard requiring reasonable suspicion)
- Rodriguez v. United States, 135 S.Ct. 1609 (2015) (traffic-stop "mission" ends when tasks tied to violation are completed; prolongation beyond mission unlawful)
- Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (consent exception to warrant requirement; voluntariness assessed from totality of circumstances)
- Brick v. State, 738 S.W.2d 676 (Tex. Crim. App. 1987) (factors for attenuation when consent follows an illegal seizure)
- State v. Mazuca, 375 S.W.3d 294 (Tex. Crim. App. 2012) (updated attenuation framework: temporal proximity, intervening circumstances, purpose/flagrancy of misconduct)
- Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (reasonable suspicion requires specific, articulable facts from totality of circumstances)