The State of Texas v. Steven Lyle Stevenson, Appellee

Summary

The Court of Criminal Appeals of Texas reversed the Court of Appeals, holding that the accident statutes did not create a custodial interrogation and that the officer’s questioning did not require Miranda warnings; therefore the appellant’s statements are admissible. The decision also notes that the trial court’s implied fact findings were improper. Justice Baird dissented, arguing that the majority ignored controlling precedent and should have deferred to the trial court’s factual determinations.