Keanu Pratt v. the State of Texas

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-25-00481-CR

Keanu PRATT,

v.

The STATE of Texas,

Appellee

From the 452nd District Court, Kimble County, Texas Trial Court No. 2024-DCR-1640 Honorable Robert Rey Hofmann, Judge Presiding

Opinion by: H. Todd McCray, Justice

Sitting: Lori I. Valenzuela, Justice Adrian A. Spears II, Justice H. Todd McCray, Justice

Delivered and Filed: August 19, 2026 AFFIRMED Appellant, Keanu Pratt, was convicted by a jury of murder and assessed punishment at confinement for life. On appeal, Pratt challenges the denial of two motions to suppress. He contends the trial court erred by admitting (1) statements he made at the scene of the crime before receiving Miranda warnings because he was subjected to custodial interrogation, and (2) a handwritten letter seized from his jail cell because jail officials obtained it through an unconstitutional warrantless search. Pratt also asserts that cumulative error requires reversal.

Because the record supports the trial court’s determination that Pratt was not in custody when he spoke with Detective Stewart and because Pratt had no reasonable expectation of privacy in the handwritten letter discovered during a lawful search of his jail cell, we affirm.

MOTIONS TO SUPPRESS

We review a trial court’s ruling on a motion to suppress under a bifurcated standard. State v. Espinosa, 666 S.W.3d 659, 667 (Tex. Crim. App. 2023); Weems v. State, 493 S.W.3d 574, 577 (Tex. Crim. App. 2016). We review the ruling in light of the totality of the circumstances, affording almost total deference to the trial court’s determination of historical facts and credibility issues that turn on witness demeanor. Sims v. State, 569 S.W.3d 634, 640 (Tex. Crim. App. 2019). We then review de novo mixed questions of law and fact that do not depend on credibility determinations, such as whether the facts establish custody for Miranda purposes or a reasonable expectation of privacy for Fourth Amendment purposes. See Alford v. State, 358 S.W.3d 647, 652– 53 (Tex. Crim. App. 2012) (Miranda); State v. Hardy, 963 S.W.2d 516, 523 (Tex. Crim. App. 1997) (Fourth Amendment). When, as here, the trial court makes no explicit findings of fact, we imply all findings necessary to support the ruling so long as those implied findings are supported by the record. Wexler v. State, 625 S.W.3d 162, 167 (Tex. Crim. App. 2021); State v. Kelly, 204 S.W.3d 808, 819 (Tex. Crim. App. 2006). We will sustain the trial court’s ruling if it is correct under any theory of law applicable to the case. State v. Ruiz, 581 S.W.3d 782, 785 (Tex. Crim. App. 2019). Under this standard, the trial court did not err in denying Pratt’s motions to suppress.

A. THE TRIAL COURT PROPERLY DENIED THE MOTION TO SUPPRESS PRATT’S STATEMENTS AT THE CRIME SCENE

In his first issue, Pratt contends the trial court erred by denying his motion to suppress body- camera video evidence of statements he made to Detective James Stewart before Stewart advised him of his rights under Miranda v. Arizona, 384 U.S. 436 (1966) and article 38.22 of the Texas

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Code of Criminal Procedure. Pratt contends he was in custody because Detective Stewart instructed him to “come here,” officers had probable cause to arrest him, and a reasonable person would not have believed he was free to leave. We disagree.

The Fifth Amendment prohibits the admission of statements obtained through custodial interrogation unless the accused first receives the warnings required by Miranda v. Arizona. See U.S. CONST. amend. V; Miranda v. Arizona, 384 U.S. 436 (1966). Article 38.22 of the Texas Code of Criminal Procedure similarly governs the admissibility of statements resulting from custodial interrogation. See TEX. CODE CRIM. PROC. art. 38.22. Neither Miranda nor article 38.22 applies, however, unless the accused is in custody or subject to a custodial interrogation. Thus, appellant was entitled to Miranda warnings only if he was in custody when Detective Stewart questioned him.

Whether a person is in custody depends upon the objective circumstances surrounding the interrogation. State v. Saenz, 411 S.W.3d 488, 496 (Tex. Crim. App. 2013). The relevant inquiry is whether a reasonable person would have understood his freedom of movement to have been restrained to the degree associated with a formal arrest. Stansbury v. California, 511 U.S. 318, 323 (1994); Dowthitt v. State, 931 S.W.2d 244, 254 (Tex. Crim. App. 1996). In making that determination, courts examine the totality of the circumstances surrounding the encounter rather than any single fact. An officer’s undisclosed subjective belief that a person is a suspect does not itself create custody. Saenz, 411 S.W.3d at 496–97. Likewise, the existence of probable cause, standing alone, does not establish custody unless that probable cause is manifested to the suspect in a manner that would cause a reasonable person to believe he is under arrest. Dowthitt, 931 S.W.2d at 255; Saenz, 411 S.W.3d at 496–97.

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While Pratt argues that Detective Stewart subjected him to custodial interrogation because Stewart directed him to come inside the crime-scene tape, questioned him about the homicide, and already possessed probable cause to arrest him, the record supports the trial court’s contrary conclusion. Viewing the evidence in the light most favorable to the ruling, Pratt voluntarily returned to the crime scene while officers were actively investigating the homicide. He approached Detective Steward himself and began conversing with him. Detective Stewart did not locate Pratt, summon him to the scene, or otherwise compel his presence. When Stewart saw Pratt approaching, Stewart simply asked him to come over and lifted the crime-scene tape so Pratt could enter the secured area to more easily speak with him. See State v. Flores, No. 08-14-00013-CR, 2016 WL 156058, at *6–8 (Tex. App.—El Paso Jan. 13, 2016, pet. ref’d) (mem. op., not designated for publication) (finding no custodial interrogation where defendant voluntarily approached the officer rather than being transported to or summoned from another location).

Nothing about the ensuing encounter reflected the degree of restraint associated with a formal arrest. Stewart displayed no weapon, made no threats, used no force, and did not physically restrain Pratt. Stewart did not instruct Pratt to raise his hands, kneel, or otherwise submit to police authority. Rather, Pratt himself approached Stewart, voluntarily raised his hands, knelt on the ground without instruction, and announced that Stewart needed to handcuff him. Stewart remained calm throughout the encounter and spoke in a conversational tone while asking Pratt what had happened and showing concern for his well-being.

Pratt argues that his encounter with Detective Stewart was a custodial interrogation because Detective Stewart had probable cause to believe he was involved in the crime. Specifically, witnesses had already identified Pratt as the assailant and officers observed blood on Pratt’s clothing. Even assuming probable cause existed, that fact alone did not convert the encounter into

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custodial interrogation. Under Dowthitt, probable cause establishes custody only when officers communicate their knowledge of probable cause to the suspect through words or actions that would cause a reasonable person to believe he was under formal arrest. 931 S.W.2d at 255. Nothing in this record reflects that Detective Stewart manifested such knowledge before Pratt made the challenged statements. See Flores, 2016 WL 156058, at *8 (holding that even assuming probable cause existed, custody did not arise because the officer never manifested that knowledge to the suspect).

Nor did the fact appellant had become the focus of the investigation render the encounter custodial. Miranda warnings are not required merely because questioning is directed toward the person officers believe committed the offense. The relevant inquiry remains whether a reasonable person would have believed he was under formal arrest. See Stansbury, 511 U.S. at 323; Dowthitt, 931 S.W.2d at 254.

Considering the totality of the circumstances, the trial court could reasonably conclude that Pratt voluntarily approached officers and participated in a brief investigative conversation rather than a custodial interrogation. Because Pratt was not in custody, Miranda and article 38.22 are not implicated. Therefore, the trial court did not abuse its discretion by denying Pratt’s first motion to suppress.

Moreover, even if we were to assume the trial court erred, we would conclude such error was harmless. See TEX. R. APP. P. 44.2(a); Jones v. State, 119 S.W.3d 766, 777 (Tex. Crim. App. 2003). After Pratt was formally arrested, Texas Ranger Terry Eaton advised Pratt of his Miranda rights before conducting a recorded interview in which Pratt again admitted assaulting and killing the victim while asserting self-defense. Pratt likewise testified at trial and admitted to killing the victim. In light of the properly admitted evidence establishing substantially the same facts as the

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challenged statements, any error in admitting Detective Stewart’s body-camera recording could not have had a substantial and injurious effect on the jury’s verdict. See Eggert v. State, 395 S.W.3d 240, 244 (Tex. App.—San Antonio 2012, no pet.) (citing Brooks v. State, 990 S.W.2d 278, 287 (Tex. Crim. App.1999)). Pratt’s first issue is overruled.

B. THE TRIAL COURT PROPERLY DENIED THE MOTION TO SUPPRESS A LETTER SEIZED FROM PRATT’S JAIL CELL.

In his second issue, Pratt contends the trial court erred by denying his motion to suppress a handwritten letter discovered during a routine administrative search of his jail cell. Relying principally on State v. Granville, 423 S.W.3d 399 (Tex. Crim. App. 2014), Pratt argues he retained a reasonable expectation of privacy in the letter, and therefore, jail officials were required to obtain a warrant before examining or seizing it. We disagree.

At the suppression hearing, jail administrator Monica Harames testified that jail officials periodically conduct administrative searches for contraband, weapons, hoarded medication, and writings that could threaten institutional security. She further testified that inmates are advised through the inmate handbook that such searches could occur. During the search at issue, a jailer discovered a notebook containing what appeared to be a written confession among Pratt’s personal belongings. After confirming the notebook belonged to Pratt, jail officials confiscated the notebook and photographed its contents.

The dispositive question is whether Pratt retained a reasonable expectation of privacy in the notebook and letter found in his jail cell. If he did not, the Fourth Amendment was not implicated in the inspection and seizure of those materials. The Fourth Amendment protects individuals against unreasonable searches and seizures only where they possess a legitimate expectation of privacy. See U.S. CONST. amend. IV. Legitimate expectations of privacy are those

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that society is prepared to recognize as objectively reasonable. Katz v. United States, 389 U.S. 347, 351–52 (1967); Villarreal v. State, 935 S.W.2d 134, 138 (Tex. Crim. App. 1996).

Although incarceration does not strip inmates of every constitutional protection, imprisonment necessarily entails substantial limitations upon privacy. Bell v. Wolfish, 441 U.S. 520, 556–57 (1979) (“[G]iven the realities of institutional confinement, any reasonable expectation of privacy that a detainee retained necessarily would be of a diminished scope.”). Accordingly, the United States Supreme Court has established that inmates generally possess no reasonable expectation of privacy in their jail cells or the personal property maintained within those cells. See Hudson v. Palmer, 468 U.S. 517, 526 (1984). The Texas Court of Criminal Appeals has likewise recognized the lack of a reasonable expectation of privacy in jail cells. See Oles v. State, 993 S.W.2d 103, 108 (Tex. Crim. App. 1999); Soria v. State, 933 S.W.2d 46, 57–59 (Tex. Crim. App. 1996).

Texas courts have consistently applied this principle to inmate correspondence. In Merritt v. State, for example, the First Court of Appeals held an inmate failed to establish a legitimate expectation of privacy in a letter intercepted by jail officials, emphasizing both the inmate handbook’s warning that nonprivileged mail would be inspected and the longstanding recognition that prison mail may be examined by correctional authorities. 982 S.W.2d 634, 635 (Tex. App.— Houston [1st Dist.] 1998, pet. ref’d). Likewise, in Brown v. State, the Twelfth Court of Appeals concluded that because inmates possess no reasonable expectation of privacy under Hudson, correctional officers did not violate the Fourth Amendment by obtaining copies of an inmate’s non-legal correspondence without first obtaining a warrant. 334 S.W.3d 789, 805 (Tex. App.— Tyler 2010, pet. ref’d); see also Thomas v. Allsip, 836 S.W.2d 825, 828 (Tex. App.—Tyler 1992,

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no writ) (holding prison officials’ inspection of an inmate’s nonlegal mail did not violate constitutional privacy rights).

These authorities are instructive. Pratt’s notebook and letter were not discovered during an investigatory search undertaken to gather evidence of a crime. Rather, they were discovered during a routine administrative search of his jail cell conducted for legitimate institutional-security purposes. Because Pratt possessed no objectively reasonable expectation of privacy in property maintained within his jail cell, jail officials did not violate the Fourth Amendment by examining, photographing, and preserving the letter they lawfully discovered during that search. See Hudson, 468 U.S. at 525–30; Soria, 933 S.W.2d at 57–59.

Pratt’s reliance on Granville is misplaced. Granville involved law enforcement’s warrantless search of the digital contents of a cellular telephone after the telephone had already been lawfully seized from an arrestee during booking. 423 S.W.3d at 401–03. Although the physical telephone had been lawfully seized, the Court of Criminal Appeals concluded that the defendant retained a reasonable expectation of privacy in the extensive personal information stored electronically within the device. Id. at 417–18. Accordingly, the court held that the subsequent investigatory search of the digital information implicated the Fourth Amendment. Id.

Unlike Granville, this case does not involve property in which Pratt retained a constitutionally protected privacy interest. In this case, because there is no reasonable expectation of privacy in papers maintained within a jail cell, the Fourth Amendment was not implicated by the administrative search that led to the letter’s discovery. Thus, this case never reaches the question of whether officers were required to obtain a warrant before searching property in which the defendant retained a protected privacy interest. Because the threshold premise underlying Granville is absent here, that decision does not control.

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Pratt nevertheless suggests the notebook should receive greater constitutional protection because inmates are permitted to possess legal papers in their cells. That argument conflates an inmate’s ability to possess property with a reasonable expectation of privacy in that property. The Fourth Amendment protects the latter, not the former. Even assuming the notebook constituted authorized inmate property, Hudson establishes that inmates possess no reasonable expectation of privacy in the property kept within their cells. Moreover, nothing in this record indicates the seized letter constituted privileged attorney-client correspondence. It was addressed to the President, not to counsel, and nothing on its face suggested it was a legal document.

Because Pratt failed to establish a legitimate expectation of privacy in the notebook or letter discovered during the routine administrative search of his jail cell, the warrantless inspection and seizure of those materials did not violate the Fourth Amendment. The trial court therefore did not err by denying Pratt’s motion to suppress the letter. Pratt’s second issue is overruled.

C. CUMULATIVE ERROR Finally, Pratt contends the cumulative effect of the asserted errors deprived him of a fair trial. The cumulative-error doctrine applies only when multiple errors, although individually harmless, collectively deny a defendant a fair trial. See Chamberlain v. State, 998 S.W.2d 230, 238 (Tex. Crim. App. 1999). Because we have found no error, there is no cumulative error to aggregate. See Reyes v. State, 717 S.W.3d 52, 70 (Tex. App.—San Antonio 2025, pet. ref’d). Pratt’s third issue is overruled.

CONCLUSION

Having overruled each of Pratt’s issues, we affirm the trial court’s judgment.

H. Todd McCray, Justice

DO NOT PUBLISH