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

Summary

The Court of Criminal Appeals affirmed the lower appellate court's judgment, holding that the Court of Appeals did not exceed its remand instructions and that the warrantless arrest of appellant was valid under Art. 14.01(b) because probable cause existed based on a reliable informant and corroborating surveillance. The Court also affirmed the admissibility of the search incident to that arrest. Two dissenting opinions argued that the majority misapplied Art. 14.01(b) and exceeded the scope of the remand.