James Joseph Luckenbach v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJune 27, 2025
Docket03-23-00368-CR
StatusPublished

This text of James Joseph Luckenbach v. the State of Texas (James Joseph Luckenbach v. the State of Texas) 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
James Joseph Luckenbach v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-23-00368-CR

James Joseph Luckenbach, Appellant

v.

The State of Texas, Appellee

FROM THE 33RD DISTRICT COURT OF BURNET COUNTY NO. 52770, THE HONORABLE J. ALLAN GARRETT, JUDGE PRESIDING

OPINION

James Joseph Luckenbach pleaded guilty to the capital murder of multiple

persons. See Tex. Penal Code § 19.03(a)(7). The State initially sought the death penalty but

agreed to waive it after the plea agreement, and the district court assessed punishment at life

imprisonment without the possibility of parole. See id. § 12.31(a). On appeal, Luckenbach

challenges the district court’s denial of his pretrial motion to suppress his incriminating

statements to police. See Tex. Code Crim. Proc. art. 44.02. He contends that he made those

statements only after he was in custody, received Miranda warnings, invoked his right to

counsel, and was told by police that a statement could “better [his] situation.” See Miranda

v. Arizona, 384 U.S. 436, 478-79 (1966). He also contends that the district court erred by

declining to strike the venire panel that received an erroneous summons instructing prospective jurors to report for jury service on a date in 2022, instead of 2023. We will reverse the district

court’s judgment of conviction and remand this cause to the district court.

BACKGROUND

The suppression hearing began with evidence about the events leading to

Luckenbach’s arrest. The Burnet County Sheriff’s Office (BCSO) responded to a report of two

deceased individuals at a residence off Highway 71. Three days later, shortly after midnight,

BCSO Deputy Brian Knowles was leaving the sheriff’s office in his patrol car when a dispatcher

flagged him down and told him that someone, later identified as Luckenbach, was in the lobby of

the sheriff’s office to turn himself in for the double homicide. Deputy Knowles drove to the

front of the sheriff’s office where he saw a truck in visitor parking and a person on the other side

of it, who identified himself as Jeff Mallett. The bodycam recording of Deputy Knowles’s

parking-lot conversation with Mallett was admitted into evidence at the hearing.

Mallett told Deputy Knowles that his friend, James Luckenbach, “who works for

the company” was there to turn himself in for “the double homicide they had in Horseshoe Bay.”

Mallett said that he had spent four hours talking Luckenbach out of killing himself, and that

Luckenbach’s pistol along with Mallett’s pistol were in Mallett’s truck. Mallett told Deputy

Knowles, “James has got representation.” He added that although Luckenbach had confessed to

him all day, Mallett was “going to have to talk to the investigators and let ‘em know what’s

going on” because Luckenbach was “not going to say anything.” Deputy Knowles asked, “Ok,

he said he’s not?” Mallett confirmed, “No, he’s not.” Deputy Knowles went inside the sheriff’s

office to speak with Luckenbach, who was later questioned by Texas Rangers.

2 The parties dispute, among other things, whether Luckenbach invoked his right to

counsel while in custody. During the suppression hearing, the district court admitted into

evidence video recordings of four separate interactions between law-enforcement officers and

Luckenbach, depicting the events between his early-morning arrival at the sheriff’s office and his

transport to jail hours later. Texas Ranger Cody Mitchell and BCSO deputies Knowles and John

Michael Talamantez testified at the hearing.

In his interactions with law enforcement, Luckenbach said that he had an attorney,

that they would go through what they had when he arrived, that he promised to wait for the

attorney and take guidance from him, and that he would like to wait for his attorney. Ranger

Mitchell confirmed to Luckenbach that the person named “Jeff” who brought Luckenbach to the

sheriff’s office had called an attorney, who was “en route.” Luckenbach was unaware that

Mallett told Ranger Mitchell beforehand that he lied to Luckenbach to get him to the sheriff’s

office and further that another officer—Ranger Nick Hill—learned about this “ruse”

from Mallett.

Deputy Knowles’s interaction with Luckenbach

When Deputy Knowles went into the sheriff’s office lobby after speaking with

Mallett, he introduced himself to Luckenbach and said that he understood Luckenbach was there

to turn himself in. Luckenbach replied, “For questioning, yes sir.” Deputy Knowles asked to pat

down Luckenbach and for him to turn around. Luckenbach complied and said that he had “never

been arrested.” Less than a minute after encountering Luckenbach, Deputy Knowles detained

him in handcuffs. He told Luckenbach that he was not under arrest but was keeping him

handcuffed until another deputy arrived. Luckenbach said he had a “bad shoulder” and asked if

3 he could be handcuffed with his hands in front of him. Deputy Knowles did not do that but used

two sets of handcuffs and adjusted one so that Luckenbach could turn his wrist with his hands

cuffed behind him.

Deputy Knowles reiterated that Luckenbach was not under arrest, “just detained,”

and Luckenbach said, “I know.” Deputy Knowles asked if Luckenbach wanted to speak to

detectives. Luckenbach said he had an attorney representing him and when his attorney arrived,

they would “go through” what they had:

Deputy Knowles: You wish to speak to the detectives, or you don’t want to?

Luckenbach: I am here because I have an attorney representing me.

Knowles: Okay.

Luckenbach: Jeff has already contacted the attorney. In fact, he’s probably on the phone with him now.

Luckenbach: He should be. And uh, as soon as my attorney gets here, we will go through what we have.

Knowles: Okay. Fair enough. I’m just gonna grab your ID.

After Deputy Knowles radioed for a driver’s license check, he asked Luckenbach about the

attorney:

Knowles: You said your attorney is en route?

Luckenbach: He’s—Jeff is supposed to be calling my attorney. He said he’d be en route as soon as I turned myself in, so hopefully he’s calling him.

Deputy Knowles asked if Luckenbach needed water or anything else, but Luckenbach declined.

4 About 8 minutes after handcuffing Luckenbach and after a radio call with BCSO

Deputy Richard Ciolfi, Deputy Knowles removed the handcuffs. He said they were used until he

could figure out what was going on and because officers had taken a firearm from Luckenbach.

Luckenbach mentioned that he had threatened to kill himself. After a short pause, he said,

“Hopefully he’s called the attorney.”

Moments later, Deputy Ciolfi advised Deputy Knowles that the Criminal

Investigative Division wanted Luckenbach detained in handcuffs and Mirandized. Deputy

Knowles told Luckenbach that his partner was going to check with Luckenbach’s “boss” 1 to see

if in fact Luckenbach’s “lawyer or representation” was coming. Deputy Knowles said, “I don’t

know how long—I think they’re getting a hold of investigators to come down to speak with you

and your representation, but I don’t have a specific timeline for that.” This time, Deputy

Knowles handcuffed Luckenbach with his hands in front. Luckenbach asked, “This is just for

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