Sammy Joe Adkins, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals of Texas affirmed the conviction, holding that the warrantless arrest of Sammy Joe Adkins was valid under Art. 14.01(b) because probable cause existed, and that the intermediate appellate court had authority to review beyond the remand instructions. Justice Teague and Justice Clinton dissented, arguing that the statute requires an offense actually be committed in the officer's presence, not merely probable cause.