Gary McGruder v. State

CourtCourt of Appeals of Texas
DecidedJanuary 22, 2020
Docket10-19-00064-CR
StatusPublished

This text of Gary McGruder v. State (Gary McGruder v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gary McGruder v. State, (Tex. Ct. App. 2020).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-19-00064-CR

GARY MCGRUDER, Appellant v.

THE STATE OF TEXAS, Appellee

From the 85th District Court Brazos County, Texas Trial Court No. 17-04501-CRF-85

MEMORANDUM OPINION

In three issues, appellant, Gary Wayne McGruder, challenges his conviction for

burglary of a habitation. See TEX. PENAL CODE ANN. § 30.02(a), (c)(2) (West 2019).

Specifically, McGruder contends that: (1) the trial court erred by failing to suppress

statements made as a result of custodial interrogation prior to his arrest; (2) the trial court

erred by refusing to instruct the jury on the lesser-included offense of theft; and (3) there is not sufficient evidence to support his conviction. Because we overrule all of

McGruder’s issues on appeal, we affirm.

I. MCGRUDER’S MOTION TO SUPPRESS

In his first issue, McGruder asserts that he was subjected to extensive interrogation

before he had been advised of his rights not to speak to officers and to have an attorney

present during questioning. Because of this purported constitutional violation,

McGruder contends that the trial court erred by failing to suppress statements made as a

result of the alleged custodial interrogation.

A. Standard of Review

We review a trial court's ruling on a motion to suppress evidence for an abuse of

discretion and overturn the ruling only if it is arbitrary, unreasonable, or “outside the

zone of reasonable disagreement.” State v. Story, 445 S.W.3d 729, 732 (Tex. Crim. App.

2014); State v. Dixon, 206 S.W.3d 587, 590 (Tex. Crim. App. 2006). We give almost complete

deference to the trial court's determination of historical facts, but we review the court's

application of the law to those facts de novo. Story, 445 S.W.3d at 732; Dixon, 206 S.W.3d

at 590.

B. Applicable Law

In deciding whether an individual was in custody, we take the findings that are

supported by the record and determine whether they constitute a Miranda custody

situation as a matter of law. State v. Saenz, 411 S.W.3d 488, 494 (Tex. Crim. App. 2013).

McGruder v. State Page 2 Central to this issue is whether McGruder demonstrated that his questioning by law

enforcement at the scene was a “custodial interrogation.” The defendant bears the

burden of proving that a statement was the product of a custodial interrogation. Herrera

v. State, 241 S.W.3d 520, 526 (Tex. Crim. App. 2007). Custodial interrogation refers to

“questioning initiated by law enforcement officers after a person has been taken into

custody or otherwise deprived of his freedom of action in any significant way.” Miranda

v. Arizona, 384 U.S. 436, 444, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966). Miranda provides that

a defendant's statements “stemming from custodial interrogation” are inadmissible as

evidence against him unless he is advised of certain constitutional rights under the Fifth

Amendment. Id. (“Prior to any questioning, the person must be warned that he has a

right to remain silent, that any statement he does make may be used as evidence against

him, and that he has a right to the presence of an attorney, either retained or appointed.”);

see U.S. CONST. amend. V.

The state counterpart is article 38.22 of the Code of Criminal Procedure, which

similarly provides that a defendant's oral statement “made as a result of custodial

interrogation” is inadmissible in a criminal proceeding unless a recording is made of the

statement, the defendant is warned during the recording but before making the statement

that “any statement he makes may be used as evidence against him in court,” and he

knowingly, intelligently, and voluntarily waives those rights. TEX. CODE CRIM. PROC.

ANN. art. 38.22, § 3(a)(1)-(2) (West 2018); see Herrera, 241 S.W.3d at 526 (stating that

McGruder v. State Page 3 construction of “custody” for purposes of article 38.22 of Texas Code of Criminal

Procedure is consistent with meaning of "custody" for purposes of Miranda and Fifth

Amendment). Statements that do not “stem from custodial interrogation” are not

precluded by article 38.22. TEX. CODE CRIM. PROC. ANN. art. 38.22, § 5.

In Dowthitt, the Court of Criminal Appeals identified four situations that may

constitute custody: (1) when the suspect is physically deprived of his freedom of action

in any significant way; (2) when a law-enforcement officer tells the suspect that he cannot

leave; (3) when law-enforcement officers create a situation that would lead a reasonable

person to believe that his freedom of movement has been significantly restricted; and (4)

when there is probable cause to arrest and law-enforcement officers do not tell the suspect

that he is free to leave. Dowthitt v. State, 931 S.W.2d 244, 255 (Tex. Crim. App. 1996).

Regarding the first through third situations, the restriction on the suspect's freedom of

movement must be to the degree associated with an arrest as opposed to an investigative

detention. Id.

Noncustodial investigative detentions and arrests both involve a restraint on an

individual's freedom of movement, but an arrest involves a comparatively greater

restraint. State v. Sheppard, 271 S.W.3d 281, 290 (Tex. Crim. App. 2008). No bright-line

test distinguishes investigative detentions from arrests; rather, courts consider several

factors to determine whether an individual is in custody, including the amount of force

displayed; the duration of the detention; the efficiency of the investigative process and

McGruder v. State Page 4 whether it is conducted at the original location or the individual is transported to another

location; the officer's expressed intent, i.e., whether he told the individual that he was

under arrest or was being detained only for a temporary investigation; and any other

relevant factors. Id. at 291. A detention is not an arrest if the degree of incapacitation is

no more than necessary to safeguard the officers and assure the suspect's presence during

a period of investigation. See id. Ultimately, courts must determine whether, given the

circumstances surrounding the interrogation, a reasonable person would have perceived

detention by law-enforcement officers to be a restraint on his movement comparable to

the restraint of formal arrest. Berkemer v. McCarty, 468 U.S. 420, 441, 104 S. Ct. 3138, 82 L.

Ed. 2d 317 (1984); Herrera, 241 S.W.3d at 525. Assessment of whether an individual is in

custody is made on an ad hoc, case-by-case basis. Dowthitt, 931 S.W.2d at 255.

C. Discussion

At the hearing on McGruder’s motions to suppress, Officer Jason Arnold of the

College Station Police Department testified that he was serving as a courtesy officer for

the Cedar Ridge apartment complex. During his night patrol, at 4:30 a.m., Officer Arnold

saw a male, later identified as McGruder, in dark clothing walking quickly from Building

5.

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