Court of Criminal Appeals of Texas
The State of Texas v. Steven Lyle Stevenson, Appellee
December 10, 19971997 Tex. Crim. App. LEXIS 106
Summary
The Court of Criminal Appeals of Texas reversed the Court of Appeals, holding that Texas accident statutes §§38‑45 do not create a privilege or duty that makes the appellant's oral statements inadmissible, and that the officer's questioning was not custodial for Miranda purposes, so the statements are admissible. Justice Baird dissented, arguing the majority should defer to the trial court’s factual findings under Guzman.