Jimmie Davis Watson, Appellant v. the State of Texas, Appellee

Summary

The Texas Court of Criminal Appeals reversed the conviction of Jimmie Davis Watson and remanded for a new trial, holding that his post‑Miranda silence constituted an invocation of his Fifth Amendment right to remain silent, that the police failed to scrupulously honor that right, and that the State did not prove a knowing, intelligent, and voluntary waiver. The court rejected the lower court’s view that an explicit statement was required to invoke the right.