Martinez v. Texas (original by judge keel)
Annotate this CaseAfter the trial court denied his motion to suppress his confession, Appellant Jesse Martinez pled guilty to murder and was sentenced to 30 years in prison. Appellant was 19 years old, had no prior arrests, and had never before been questioned by the police. In April 2016, police officers arrived at his mother's house after midnight without a warrant for the purpose of questioning him about the disappearance of his friend, Tristan Mina. They took him to the police station in an unmarked car. His mother followed in her own car and waited in the family area when they took him to an interrogation room. She told him that she would get him an attorney. Appellant waited in the interrogation room alone for several minutes before two detectives, Michael Lara and Rex Parsons, joined him there. Detective Lara read Appellant his Miranda rights. Appellant invoked his right to counsel, and the interview was terminated. The detectives told Appellant that he was under arrest for murder and locked him in a holding cell where he was handcuffed to a bench. Less than fifteen minutes later Appellant "flagged down" Lara and said he would give a statement. Appellant was returned to the interrogation room and was again read his Miranda rights. He said he understood the rights and wished to continue. He then gave an hour-long videotaped statement recounting the events of the night that Mina was killed. On appeal he challenged the suppression ruling, claiming that his confession was the product of an illegal arrest. The court of appeals held that the taint was sufficiently attenuated under Brown v. Illinois, 422 U.S. 590 (1975), and affirmed the trial court. The Texas Court of Criminal Appeals granted review of this matter to determine whether the court of appeals misapplied the four-factor test from Brown and whether the court of appeals' finding of probable cause was based on opinions rather than facts in conflict with Torres v. Texas, 182 S.W.3d 899 (Tex. Crim. App. 2005). The Court concluded the court of appeals misapplied the third and fourth Brown factors and erred in looking to Appellant's statement to establish probable cause for his arrest. Judgment was therefore reversed and the case remanded to the trial court for further proceedings.
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