York v. State
2011 Tex. Crim. App. LEXIS 913
| Tex. Crim. App. | 2011Background
- Officer Johnson observed York sleeping in a running vehicle parked partially on a sidewalk in front of an Exxon in Smith County at about 3:00 a.m.; the station had prior burglaries, and the officer knew of related incidents near that location.
- The headlights shone into the store, York appeared unoccupied, and the officer approached on foot after parking.
- York woke when addressed; he lacked a license, gave a confused location, and consented to a protective search which yielded marijuana and methamphetamine.
- Earlier, York was prosecuted in county court for failure to identify; the judge suppressed evidence, granted a directed verdict, and told the jury there was no evidence.
- A subsequent district-court prosecution for possession of methamphetamine involved suppression and collateral-estoppel arguments; evidence from the first case was used in the second for argument purposes.
- The Texas Court of Criminal Appeals ultimately reaffirmed that collateral estoppel does not bar relitigation of suppression issues unless the affected facts are essential elements in both prosecutions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Collateral estoppel and suppression issues | York relied on Murphy to bar relitigating suppression facts | State argued Murphy applied to bar relitigation | Collateral estoppel does not bar relitigation of suppression issues unless the fact is an essential element in the second prosecution |
| Reasonable suspicion for investigative detention | York asserts no valid detention outside jurisdiction | State shows reasonable suspicion to detain for burglary/public intoxication | Officer Johnson had reasonable suspicion to detain and investigate; detention permissible under Article 14.03(g)(2) and 14.03(d) principles |
Key Cases Cited
- Murphy v. State, 239 S.W.3d 791 (Tex.Crim.App. 2007) (collateral estoppel applies to relitigating suppression facts when appropriate)
- Ashe v. Swenson, 397 U.S. 436 (U.S. 1970) (ultimate fact essential to both prosecutions; collateral estoppel in double jeopardy)
- Ex parte Taylor, 101 S.W.3d 434 (Tex.Crim.App. 2002) (test for collateral estoppel in Texas; influence on Murphy lineage)
- Neal v. Cain, 141 F.3d 207 (5th Cir. 1998) (two-step test for collateral estoppel; whether necessarily decided facts are essential elements)
- Dowling v. United States, 493 U.S. 342 (U.S. 1990) (limits of collateral estoppel to essential elements when burden shifts)
- Oppenheimer, 242 U.S. 85 (U.S. 1916) (early collateral-estoppel/claim-preclusion context in double jeopardy)
- Wingate v. Wainwright, 464 F.2d 209 (5th Cir. 1972) (expansive view of collateral estoppel before Dowling)
- Standefer v. United States, 447 U.S. 10 (U.S. 1980) (double jeopardy limitations in criminal cases; full and fair opportunity to litigate)