State v. Meredith Carol Woehst

CourtCourt of Appeals of Texas
DecidedSeptember 16, 2004
Docket01-02-01263-CR
StatusPublished

This text of State v. Meredith Carol Woehst (State v. Meredith Carol Woehst) 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
State v. Meredith Carol Woehst, (Tex. Ct. App. 2004).

Opinion

Opinion issued September 16, 2004





In The

Court of Appeals

For The

First District of Texas





NO. 01-02-01263-CR





THE STATE OF TEXAS, Appellant


V.


MEREDITH CAROL WOEHST, Appellee





On Appeal from County Court at Law No. 2

Brazos County, Texas

Trial Court Cause No. 013432-CCL2





DISSENTING OPINION


          Because I believe appellant did not meet her burden of proof for exclusion of her refusal to take a breath test, I respectfully dissent.

          Woehst argued that, because she was not provided with the correct statutory warnings, in violation of section 724.015 of the Transportation Code, her refusal to provide a breath specimen was involuntary and, therefore, inadmissible under the self-incriminatory provisions of the federal and state constitutions and under Texas’s exclusionary rule, article 38.23 of the Texas Code of Criminal Procedure. When reviewing a trial court’s ruling on a motion to suppress, we must consider whether the trial court improperly applied the law to the facts. Porter v. State, 938 S.W.2d 725, 727 (Tex. App.—Houston [1st Dist.] 1996, pet. ref’d). While we give almost total deference to the trial court’s determination of historical facts, we conduct a de novo review of the law to those facts. Carmouche v. State, 10 S.W.3d 323, 327 (Tex. Crim. App. 2000); see also Guzman v. State, 955 S.W.2d 85, 87, 89 (Tex. Crim. App. 1997); Bachick v. State, 30 S.W.3d 549, 551 (Tex. App.—Fort Worth 2000, pet. ref’d). The majority concludes that Woehst’s testimony that the officer’s recitation of a superseded version of section 724.015 “influenced” her decision to refuse the test establishes not only factual causation, as the trial court found, but also legal causation. I disagree.

          Admissibility of Refusal Under Federal and State Constitutions

          The Supreme Court has held that a DWI suspect’s refusal to take a blood-alcohol test lawfully requested by an officer is not an act coerced by the officer and, therefore, is not protected by the Fifth Amendment and is admissible in a subsequent DWI prosecution. South Dakota v. Neville, 459 U.S. 553, 566, 103 S. Ct. 916, 923 (1983) (upholding use at trial of defendant’s refusal to provide blood sample for DWI testing where defendant was not warned refusal could be used against him at trial as required by state statute). Id. 563-64, 103 S. Ct. at 922 (citations omitted).

          In Thomas v. State, the Texas Court of Criminal Appeals, likewise, held that the admission in a DWI prosecution of a defendant’s uncompelled refusal to submit to a breath test does not violate the state constitutional privilege against self-incrimination. 723 S.W.2d 696, 704-05 (Tex. Crim. App. 1986) (expressly adopting the reasoning in Neville and finding no constitutional violation where defendant was warned his driver’s license and driver’s privileges could be suspended if he refused breath test, but was not warned his refusal could be used at trial); see also Miffleton v. State, 777 S.W.2d 76, 79-80(Tex. Crim. App. 1989). Thomas defined physical compulsion for purposes of self-incrimination in the DWI context as including “such obvious force as physical torture or extended deprivation of food and water.” Thomas, 723 S.W.2d at 704. It defined mental compulsion as including “the more subtle force associated with offering a defendant two choices, one of which results in a penalty, punishment or detriment from which the defendant is entitled to be free.” Id. Both types of compulsion, it stated, “remove the element of voluntariness from a defendant’s decision to incriminate himself.” Id. (emphasis in original).

          The court reasoned that the State could have legitimately relieved the defendant of having to choose between refusing and submitting to the test by compelling him to provide physical evidence of intoxication; instead, it attempted to influence him to provide the evidence using the threat of a penalty for refusing; by refusing, the defendant avoided what might have been compelled, but “accepted those consequences the State could legitimately apply.” Thomas, 723 S.W.2d at 705. The Court concluded, “Such difficult options do not necessarily create compulsion for a particular choice.” Id. It held that Article 1, section 10 of the Texas constitution was not violated by the State’s failure to warn the defendant that his refusal could be used against him at trial where the other statutory warnings were correct and no compulsion was used to obtain the refusal. Id.

          Here, Woehst expressly admitted that she did not feel coerced by the officer to refuse to provide a specimen and that she understood the form as it was explained to her. Nor is there any evidence that the officer used physical or mental compulsion as defined in Thomas to obtain her refusal. I would hold, therefore, that Woehst’s refusal to take a breath test is admissible under both federal and state anti-self-incrimination provisions.

          Admissibility of Refusal Under Texas’ Exclusionary Rule

          The State also contends that Woehst’s refusal should not have been suppressed under Texas’ exclusionary statute, article 38.23 of the Texas Code of Criminal Procedure. See Tex. Code Crim. Proc. Ann. art. 38.23 (Vernon Supp. 2004). It argues that (1) article 38.23 requires the exclusion only of illegally obtained evidence; (2) the refusal to give a breath specimen would be illegally obtained only if the refusal were involuntary; (3) a refusal to give a breath specimen cannot be involuntary unless it is coerced by the officer; and (4) Woehst’s refusal was not coerced; therefore, it is admissible.

          Woehst responds

Free access — add to your briefcase to read the full text and ask questions with AI

Related

South Dakota v. Neville
459 U.S. 553 (Supreme Court, 1983)
Bachick v. State
30 S.W.3d 549 (Court of Appeals of Texas, 2000)
Carmouche v. State
10 S.W.3d 323 (Court of Criminal Appeals of Texas, 2000)
Thomas v. State
723 S.W.2d 696 (Court of Criminal Appeals of Texas, 1986)
Harrison v. State
766 S.W.2d 600 (Court of Appeals of Texas, 1989)
Mody v. State
2 S.W.3d 652 (Court of Appeals of Texas, 1999)
Sandoval v. State
17 S.W.3d 792 (Court of Appeals of Texas, 2000)
Rowland v. State
983 S.W.2d 58 (Court of Appeals of Texas, 1999)
Miffleton v. State
777 S.W.2d 76 (Court of Criminal Appeals of Texas, 1989)
Erdman v. State
861 S.W.2d 890 (Court of Criminal Appeals of Texas, 1993)
Owens v. State
861 S.W.2d 419 (Court of Appeals of Texas, 1993)
Moore v. State
981 S.W.2d 701 (Court of Appeals of Texas, 1998)
State v. Daugherty
931 S.W.2d 268 (Court of Criminal Appeals of Texas, 1996)
Roquemore v. State
60 S.W.3d 862 (Court of Criminal Appeals of Texas, 2001)
Schafer v. State
95 S.W.3d 452 (Court of Appeals of Texas, 2003)
Gonzales v. State
67 S.W.3d 910 (Court of Criminal Appeals of Texas, 2002)
Nebes v. State
743 S.W.2d 729 (Court of Appeals of Texas, 1987)
Jessup v. State
935 S.W.2d 508 (Court of Appeals of Texas, 1996)
Porter v. State
938 S.W.2d 725 (Court of Appeals of Texas, 1996)
Lane v. State
951 S.W.2d 242 (Court of Appeals of Texas, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Meredith Carol Woehst, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-meredith-carol-woehst-texapp-2004.