Background

• Taunton appeals two convictions (capital murder and murder) arising from consolidated trial; sentences were life without parole in the capital case and life imprisonment in the murder case.
• Appellant challenged searches of a pickup truck, box trailer, and rental car in Louisiana via search warrants based on affidavits.
• Motion to suppress argued the supporting affidavits lacked probable cause to describe the offenses, the evidence, or the locations.
• Affidavits were described as “bare bones,” containing conclusory statements with no facts linking the murders to Taunton or to the items sought.
• The trial court denied the motion to suppress, adopted the State’s proposed findings of fact, and Taunton sought reversal and remand for a new trial.
• Oral argument was waived and the State’s case proceeded to trial with the challenged evidence as part of the record.

Issues

Key Cases Cited

• Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable-cause review of affidavits in light of totality of the circumstances)
• Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusion of illegally obtained evidence in state courts)
• Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (limits on vehicle searches incident to arrest; need for warrant or exception without reaching for evidence not within reach)
• Huddleston, 387 S.W.3d 33 (Tex. App.—Texarkana 2012) (probable-cause analysis limited to four corners of affidavit; de novo review of legality)
• Delgado v. State, 718 S.W.2d 718 (Tex. Crim. App. 1986) (standards for suppressing improperly obtained evidence; relevance to affidavits)
• Gutierrez v. State, 221 S.W.3d 680 (Tex. Crim. App. 2007) (requirement to prove warrant exception or lack of warrant)
• Florida v. Wells, 495 U.S. 1 (U.S. 1990) (inventory-search limits; not a pretext for crime discovery)
• Trujillo v. State, 952 S.W.2d 879 (Tex. App.—Dallas 1997) (inventory/search procedures and standards)
• Uballe v. State, 439 S.W.3d 380 (Tex. App.—Amarillo 2014) (limitations on inventory-search justification)