Texas v. Mata (original by presiding judge keller)
Annotate this CaseA fifteen-year-old girl was kidnapped. Appellee Ricardo Mata called the girl’s mother and demanded a ransom of $300 for her release. He said this was the amount he had “paid” for her. A sheriff's investigator posed as a friend of the mother to negotiate the trade. While on the phone, the investigator had Appellee's cell phone "pinged," and they were able to trace the phone's location. Appellee left the house in a vehicle, and the phone’s “pinged” location matched his movements. At some point Appellee mentioned that his battery was dying; investigators had a marked police car stop Appellee’s vehicle. Investigators arrived on the scene and questioned Appellee regarding the kidnapped girl. They did not administer Miranda warnings. One investigator immediately accused Appellee of being the kidnapper and said that “they got him.” After further “aggressive interrogation,” Appellee said he would help locate the girl if they let him go. The investigator responded that Appellee would not be free to leave. After continued interrogation, Appellee revealed the child’s location. Once she was found, Appellee was transported to the sheriff’s office. Appellee filed a motion to suppress statements made by him to law enforcement, contending the investigators did not give him Miranda warnings. The trial court agreed, suppressing any “statements alleged to have been made by [Appellee] at the time he was detained on the side of the road and in response to direct questioning from Investigator Porraz, Chavez, and or Deputy Canales.” The trial court found that Appellee was “not free to leave the side of the road” at the time he gave the roadside statements and that Miranda warnings had not been given. On appeal, the State argued that the roadside questioning fell within the public safety exception to the Miranda rule and that the resulting statements were admissible. The court of appeals disagreed, holding that the public safety “exception is a narrow one, and it has only been used in situations involving the use of guns.” The appellate court concluded that “the officers had no indication of a weapon or gun being involved or used to endanger the safety of the public,” and the court declined to construe the public safety exception more broadly because that “may lessen the clarity of the Miranda rule.” The Texas Court of Criminal Appeals reversed both the trial and appellate courts, finding the "public safety" exception to Miranda extended to attempts to find a kidnapped child.
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