The State of Texas v. Manuel Rios

CourtCourt of Appeals of Texas
DecidedJuly 17, 2025
Docket07-24-00366-CR
StatusPublished

This text of The State of Texas v. Manuel Rios (The State of Texas v. Manuel Rios) 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
The State of Texas v. Manuel Rios, (Tex. Ct. App. 2025).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-24-00366-CR

THE STATE OF TEXAS, APPELLANT

V.

MANUEL RIOS, APPELLEE

On Appeal from the 364th District Court Lubbock County, Texas Trial Court No. DC-2024-CR-1802, Honorable William R. Eichman II, Presiding

July 17, 2025 MEMORANDUM OPINION Before QUINN, C.J., and DOSS and YARBROUGH, JJ.

This case tests whether Texas Code of Criminal Procedure Article 38.23(b)’s good

faith exception applies when a search warrant affidavit was sworn before an official

authorized to administer oaths—but not the specific official required by statute. The State

of Texas appeals from the trial court’s order suppressing evidence pursuant to Appellee

Manuel Rios’s motion. By a single issue, the State argues that although the affidavit for

a search warrant did not strictly comply with Code of Criminal Procedure Article 18.0215(c), the officers acted in good faith. We agree with the State, and reverse and

remand.

BACKGROUND

The pertinent facts are straightforward. A grand jury indicted Rios on six counts of

sexual assault1 and one count of attempted sexual assault. Billy Koontz, a certified peace

officer and investigator with the Lubbock County District Attorney’s Office, completed an

affidavit seeking a search warrant for Rios’s cell phone. Chief Investigator Brent Rose,

another certified peace officer and Koontz’s supervisor, administered the oath to Koontz

for the affidavit. Koontz then emailed his signed affidavit and an unsigned warrant to

District Judge Les Hatch, who found probable cause existed and signed the warrant.

None of the three men—Judge Hatch, Koontz, or Rose—knew that Texas Code of

Criminal Procedure Article 18.0215(c) required the application be “sworn to or affirmed

before the judge.”

Rios moved to suppress evidence recovered from the cell phone on multiple

grounds. The trial court found probable cause existed but agreed with Rios that because

Koontz did not swear the affidavit before a judge as required by Article 18.0215(c), the

failure “amounted to no oath at all.”

ANALYSIS

Legal Framework

1 See TEX. PENAL CODE ANN. § 22.011(a).

2 Texas Code of Criminal Procedure Article 18.01(b) establishes foundational

requirements for search warrants:

No search warrant shall issue for any purpose in this state unless sufficient facts are first presented to satisfy the issuing magistrate that probable cause does in fact exist for its issuance. A sworn affidavit setting forth substantial facts establishing probable cause shall be filed in every instance in which a search warrant is requested.

TEX. CODE CRIM. PROC. ANN. art. 18.01(a), (b).

Under the general rule, various officials may administer the required oath, including

peace officers. See TEX. GOV’T CODE ANN. § 602.002(18); see also Ashcraft v. State, No.

03-12-00660-CR, 2013 Tex. App. LEXIS 10402, at *16 (Tex. App.—Austin Aug. 20, 2013,

no pet.) (mem. op., not designated for publication). The purpose of requiring an oath is

to call upon the affiant’s sense of moral duty to tell the truth and to instill a sense of

seriousness and responsibility. Smith v. State, 207 S.W.3d 787, 790 (Tex. Crim. App.

2006).

Article 18.0215, however, establishes heightened requirements for cellular

telephone searches. Article 18.0215(c) mandates that cell phone warrant applications

“must be written and signed and sworn to or affirmed before the judge.” TEX. CODE CRIM

PROC. ANN. art. 18.0215(c). This provision reflects the legislature’s recognition of the

unique privacy interests implicated by cellular telephone searches.

The Good Faith Exception

A trial court must exclude evidence obtained in violation of the Constitution or laws

of Texas or the United States unless the “evidence was obtained by a law enforcement

officer acting in objective good faith reliance upon a warrant issued by a neutral magistrate 3 based on probable cause.” Id. art. 38.23(a), (b). The State bears the burden of proving

the exception’s applicability. Wheeler v. State, 616 S.W.3d 858, 866 (Tex. Crim. App.

2021). The good faith exception applies when the prior law enforcement conduct was

“close enough to the line of validity that an objectively reasonable officer preparing the

affidavit or executing the warrant would believe that the information supporting the

warrant was not tainted by unconstitutional conduct.” McClintock v. State, 541 S.W.3d

63, 73 (Tex. Crim. App. 2017).

Distinguishing Wheeler

In Wheeler, the Court of Criminal Appeals addressed whether the good faith

exception applied when officers submitted a completely unsworn affidavit for a blood

search warrant. 616 S.W.3d at 866. The court held the good faith exception did not apply

because submitting an unsworn affidavit violated both long-standing federal constitutional

requirements and state statutory mandates that warrants may only issue when probable-

cause facts are sworn under oath. Id.

Critically, the Court emphasized that the defect in Wheeler was not “a mere

procedural irregularity with respect to how the affidavit was sworn” but rather that the

affidavit “was not sworn at all.” Id. at 867. The Court concluded that “[t]he complete

absence of this indispensable constitutional and statutory requirement is nowhere close

to the line of valid law enforcement conduct that would bring this situation within the ambit

of the good-faith exception.” Id.

We find Wheeler distinguishable. Although the trial court concluded the affidavit

was legally unsworn, it was in fact made under oath before an official generally authorized

4 to administer oaths. See TEX. GOV’T CODE ANN. § 602.002(18); Smith, 207 S.W.3d at

790.

The Court of Criminal Appeals has applied the good faith exception where officers

rely on warrants with technical defects that do not undermine the warrant’s constitutional

foundation. In State v. Arellano, the Court held that a defect on a warrant that failed to

meet Article 18.04(5)’s requirements (requiring a legible signature) did not preclude the

good faith exception. 600 S.W.3d 53, 60–61 (Tex. Crim. App. 2020). The Court

emphasized that “evidence obtained pursuant to such a defective warrant should not be

rendered inadmissible, so long as the statutory requirements of Article 38.23(b) are

satisfied . . . .” Id.

Similarly, in Dunn v. State, a magistrate’s missing signature on an arrest warrant

was held to be a defect covered by the good faith exception. 951 S.W.2d 478, 479 (Tex.

Crim. App. 1997). The Court held that despite the statutory violation, the record reflected

“the magistrate found probable cause to issue the warrant, signed the accompanying

warrants, and intended but inadvertently failed to sign appellant’s arrest warrant.” Id.

Objective Good Faith Analysis

The Court of Criminal Appeals has “repeatedly reminded reviewing courts that they

should not invalidate the warrant by interpreting the affidavit in a hypertechnical, rather

than a commonsense, manner.” Rodriguez v. State, 232 S.W.3d 55, 59 (Tex. Crim. App.

2007). This case involves a technical procedural violation applied to an otherwise valid

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Related

Rodriguez v. State
232 S.W.3d 55 (Court of Criminal Appeals of Texas, 2007)
Smith v. State
207 S.W.3d 787 (Court of Criminal Appeals of Texas, 2006)
Dunn v. State
951 S.W.2d 478 (Court of Criminal Appeals of Texas, 1997)
McClintock, Bradley Ray
541 S.W.3d 63 (Court of Criminal Appeals of Texas, 2017)

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