Saenz v. Texas (Original)
Annotate this CaseJust after 2 A.M., officers were dispatched to a fast food restaurant following a complaint of a disturbance between the restaurant’s customers and two intoxicated men. Upon arrival, the officer encountered two men that matched the complainant’s description; the men were sitting in a truck with the engine running in the restaurant’s parking lot. The officer told appellee three times to turn off the truck before appellee complied. Appellee had answered the officer's initial requests to turn off the truck with claims that he was not driving and that he was moving the truck for someone else. The officer had appellee exit the truck, at which time he also smelled alcohol on appellee's breath and saw that his eyes were bloodshot. To investigate his suspicion that appellee may have been driving while intoxicated, he placed appellee unhandcuffed into the back of his patrol car and called for a department DWI specialist. Appellee failed field sobriety tests and was arrested for DWI. The trial court granted appellee’s motion to suppress appellee's oral statements made to the officers. In response to the State's request, the trial court made findings of fact and conclusions of law: that the responding officer had no reasonable suspicion to detain appellee for the disturbance in the restaurant and that appellee was "under arrest for suspicion of DWI when [the DWI specialist] began questioning" him without giving him the statutory warnings. On the State's petition for discretionary review, the Supreme Court determined that the court of appeals erred: (1) by failing to apply a de novo standard of review to the trial court's ultimate legal determination that appellee was in custody when he made incriminating statements to police; and (2) by failing to abate the appeal for further findings of fact by the trial court. The case was reversed and remanded to the court of appeals with instructions to abate the case to the trial judge for supplemental findings.
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