Thai Ngoc Nguyen, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals of Texas affirmed the lower appellate court's judgment, holding that Officer Johnson's failure to complete the full statutory warnings required by Article 38.22, Section 3 of the Texas Code of Criminal Procedure rendered Nguyen's oral statement inadmissible. The majority reasoned that strict compliance with all five statutory requirements is mandatory and that no exception exists for statements that are not confessional in nature. The Court rejected the State's arguments concerning Article 38.23, custody analysis, and the "new crime" theory. Justice Johnson dissented, arguing that the incomplete warnings did not bar admission of Nguyen's statements.