Ray Mitchell Wilkerson, Appellant v. the State of Texas

Summary

The Court reversed the Court of Appeals and affirmed the trial court, holding that a Child Protective Services investigator who interviewed the defendant while he was in custody was not an agent of law enforcement for Miranda purposes, so no warnings were required and the trial court did not abuse its discretion in admitting the statement. The opinion also clarified the agency test and rejected the appellate court's formulation of "acting in tandem" as overly broad.