Court of Criminal Appeals of Texas

Robert Wallace West, Jr., Appellant v. the State of Texas, Appellee

September 17, 19861986 Tex. Crim. App. LEXIS 807

Summary

The Court affirmed West's capital murder conviction, holding that the warrantless arrest was lawful under Article 14.04 of the V.A.C.C.P. and that his confession and related evidence were admissible. The Court reasoned that the officers reasonably believed West would flee and that West never invoked his right to silence. Two dissenting judges criticized the majority for effectively rewriting the statute and for allowing warrantless arrests based on mere "eyeball-to-eyeball" contact. The dissent argues the statute requires concrete proof of imminent escape.