Jose Luis Morenocastaneda v. the State of Texas

CourtListener 10876013Txctapp6Jun 12, 2026

Full text

In the
Court of Appeals
Sixth Appellate District of Texas at Texarkana

No. 06-25-00061-CR

JOSE LUIS MORENOCASTANEDA, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 372nd District Court
Tarrant County, Texas
Trial Court No. 1789110

Before Stevens, C.J., van Cleef and Rambin, JJ.
Memorandum Opinion by Justice Rambin
MEMORANDUM OPINION

A Tarrant County1 jury convicted Jose Luis Morenocastaneda of the murder of Evila

Yanes. The trial court, adopting the jury’s assessment of punishment, sentenced

Morenocastaneda to life in prison.

The sole issue on appeal concerns two interrogations and whether Morenocastaneda’s

invocation of his right to counsel in the first interrogation carried over to the second

interrogation. In other words, Morenocastaneda does not complain of the first interrogation. He

did not confess to murder during that interrogation. Indeed, he relies on his assertion of his right

to counsel during that interrogation. Morenocastaneda does not complain of the second

interrogation either, at least not on a standalone basis. During the second interrogation,

Morenocastaneda was again advised of his right against self-incrimination and his right to

counsel. However, in that interrogation, he did not invoke his right to counsel.

Morenocastaneda proceeded to speak with his interrogators. He admitted to striking Yanes in

the head with a pipe. Morenocastaneda does not assert that, considering the second interrogation

alone, his confession was involuntary. Instead, Morenocastaneda contends that his invocation of

his right to counsel in the first interrogation rendered his confession in the second interrogation

involuntary, and thus, inadmissible. In practical effect, Morenocastaneda contends that there

never should have been a second interrogation.

1
This appeal was transferred to this Court from the Second Court of Appeals pursuant to a Texas Supreme Court
docket equalization order. See TEX. GOV’T CODE ANN. § 73.001 (Supp.). Accordingly, we apply the precedent of
the Second Court of Appeals in deciding this case to the extent that it conflicts with our own. See TEX. R. APP. P.
41.3.
2
The parties present arguments regarding the right against self-incrimination as protected

by Miranda v. Arizona,2 the prohibition on subsequent interrogations after a party has invoked

their right to counsel as set forth in Edwards v. Arizona,3 and the exception to Edwards when

there has been a “break in custody” as described by Maryland v. Shatzer.4 In sum, this case turns

on whether there was a “break in custody” between the first interrogation and the second.

The trial court denied Morenocastaneda’s motion to suppress the confession made in the

second interrogation. We decide this appeal under a bifurcated standard of review, which shows

deference to the trial court’s fact-findings, both actual and implied. Under that standard of

review, we affirm the trial court’s denial of Morenocastaneda’s motion to suppress. Since the

trial court’s ruling on the motion to suppress is the sole issue on appeal,5 we also affirm the trial

court’s judgment.

I. Overview of Relevant Authority Regarding Confessions

“The warnings set out by the United States Supreme Court in Miranda v. Arizona were

established to safeguard an uncounseled individual’s constitutional privilege against self-

incrimination during custodial interrogation.” Herrera v. State, 241 S.W.3d 520, 525 (Tex.

Crim. App. 2007) (citing Miranda, 384 U.S. at 467–79). In 1981, in Edwards, the United States

Supreme Court held that “it is inconsistent with Miranda and its progeny for the authorities, at

2
Miranda v. Arizona, 384 U.S. 436, 467 (1966).
3
Edwards v. Arizona, 451 U.S. 477, 484–85 (1981).
4
Maryland v. Shatzer, 559 U.S. 98, 103 (2010).
5
In conjunction with contending that the admission of his confession was erroneous, Morenocastaneda contends that
its admission was harmful. The State contends that, given other evidence of Morenocastaneda’s guilt, admission of
the confession, if error, was harmless. For reasons set out herein, we do not reach the question of harm.
3
their instance, to reinterrogate an accused in custody if he has clearly asserted his right to

counsel.” Edwards, 451 U.S. at 485.6 Edwards made such post-invocation interrogations

presumptively involuntary. Id. The purpose of the Edwards rule is “to prevent police from

badgering a defendant into waiving his previously asserted Miranda rights.”7 These cases have

been referred to as “the Miranda–Edwards ‘Fifth Amendment’ right to counsel” because of the

role of counsel in protecting the Fifth Amendment8 right against self-incrimination.9 Another

term for this is “[t]he Fifth Amendment Right to Interrogation Counsel.”10

In 2010, the United States Supreme Court revisited the subject. Shatzer, 559 U.S. at 105–

06. The Supreme Court acknowledged that the Edwards rule was a judicially-created

prophylactic measure to guard against coercion after a party has invoked the right to counsel. Id.

The Supreme Court held that the Edwards rule came at a cost. Id. “Voluntary confessions are

not merely ‘a proper element in law enforcement,’ Miranda, [384 U.S. at 478], they are an

‘unmitigated good,’ . . . ‘“essential to society’s compelling interest in finding, convicting, and

6
See McNeil v. Wisconsin, 501 U.S. 171, 177 (1991); McCarthy v. State, 65 S.W.3d 47, 52 (Tex. Crim. App. 2001)
(“In sum, the Edwards rule does not take into account the good intentions of the individual police officer, the lack of
official coercion or badgering in the particular case, or the actual voluntariness of a person’s custodial statement.”);
Arizona v. Roberson, 486 U.S. 675, 683 (1988) (“[T]he presumption raised by a suspect’s request for counsel—that
he considers himself unable to deal with the pressures of custodial interrogation without legal assistance—does not
disappear simply because the police have approached the suspect, still in custody, still without counsel, about a
separate investigation.”).
7
Michigan v. Harvey, 494 U.S. 344, 350 (1990).
8
U.S. CONST. amend. V.

9
McNeil, 501 U.S. at 177.
10
Pecina v. State, 361 S.W.3d 68, 74 (Tex. Crim. App. 2012). These are shorthand phrases, though. See id. at 74
n.16. “The prophylactic Miranda warnings are ‘not themselves rights protected by the Constitution but [are] instead
measures to [e]nsure that the right against compulsory self-incrimination [is] protected.’” Duckworth v. Eagan, 492
U.S. 195, 203 (1989) (first and third alterations in original) (quoting Michigan v. Tucker, 417 U.S. 433, 444 (1974)).
4
punishing those who violate the law,”’ [McNeil, 501 U.S. at 181].” Shatzer, 559 U.S. at 108

(citations omitted). The Supreme Court expressed concern in Shatzer that a perpetual ban on

post-invocation interrogations would do more harm than good by foreclosing the possibility of

obtaining voluntary confessions. Id. at 108–09. There comes a point where the risks of coercion

have dissipated. Id. at 109. Thus, the Supreme Court announced the “break in custody”

exception to Edwards. Id. The Supreme Court set out a guideline by stating, “[Fourteen days]

provides plenty of time for the suspect to get reacclimated to his normal life, to consult with

friends and counsel, and to shake off any residual coercive effects of his prior custody.” Id. at

110.

“[C]ustody” in this context, however, refers to “Miranda custody,” which “is a term of

art that specifies circumstances that are thought generally to present a serious danger of

coercion.” Howes v. Fields, 565 U.S. 499, 507, 508–09 (2012).11 For example, being in prison

sounds like being in custody in the everyday use of the word, but it can be a break in the “serious

danger of coercion” at issue in Miranda custody.12 Id. at 509. The Texas Court of Criminal

11
See Bass v. State, 723 S.W.2d 687, 691 (Tex. Crim. App. 1986) (“Undoubtedly the legislature intended that the
term ‘custodial interrogation’ [in Article 38.22 of the Texas Code of Criminal Procedure] be construed consistently
with its meaning under the Fifth Amendment.”).
12
“[A] break in custody may occur while a suspect is serving a term in prison.” Howes, 565 U.S. at 510. “Without
minimizing the harsh realities of incarceration, we think lawful imprisonment imposed upon conviction of a crime
does not create the coercive pressures identified in Miranda.” Shatzer, 559 U.S. at 113.

[Q]uestioning a person who is already serving a prison term does not generally involve
the shock that very often accompanies arrest. In the paradigmatic Miranda situation—a person is
arrested in his home or on the street and whisked to a police station for questioning—detention
represents a sharp and ominous change, and the shock may give rise to coercive pressures.

Howes, 565 U.S. at 511. Though Howes spoke directly to what might constitute a break in custody, that was not the
question before the Supreme Court. Id. at 504. Howes involved a prisoner who was questioned without being given
Miranda warnings. Id. Consequently, the question before the Supreme Court was not whether there had been a
5
Appeals has likewise stated, “We find no basis for the assumption that the coercive aspects of

custodial interrogation are present in every instance in which an inmate is questioned by a law

enforcement officer.” Herrera, 241 S.W.3d at 531. Pertinent to present circumstances, Herrera

involved a defendant who was questioned “while he was in held in the county jail on an

unrelated offense.” Id. at 522.

A break in Miranda custody matters because

there is no reason to believe a suspect will view a confession as “‘the only way to
end his interrogation’” when, before the interrogation begins, he is told that he
can avoid it by simply requesting that he not be interrogated without counsel
present—an option that worked before. If . . . a break in custody does not change
the suspect’s mind, he need only say so.

Shatzer, 559 U.S. at 115 (quoting id. at 125 (Stevens, J. concurring)).

Consistent with the burden to show the voluntariness of confessions in other contexts, the

State bore the burden to show a Shatzer “break in custody” to avail itself of the Shatzer

exception to the Edwards rule. See McKane v. State, 726 S.W.3d 413, 421 (Tex. Crim. App.

2025), appeal docketed, No. 25-7055 (U.S. Mar. 18, 2026) (“The State bears the burden of

proving a knowing, intelligent, and voluntary waiver by a preponderance of the evidence.”

(citing Joseph v. State, 309 S.W.3d 20, 24 (Tex. Crim. App. 2010))).13

With these concepts in mind, we turn to the facts and arguments in this case.

Shatzer “break in custody” between two Mirandized interrogations, but instead was whether the prison interrogation
took place under circumstances that amounted to Miranda custody and therefore required Miranda warnings. Id. at
517 (“[W]e hold that respondent was not in custody within the meaning of Miranda.”).
13
See Rodriquez v. State, No. 07-22-00257-CR, 2023 WL 4714080, at *2 (Tex. App.—Amarillo July 24, 2023, pet.
ref’d) (mem. op., not designated for publication). The State embraces the burden to show a Shatzer “break in
custody.” We therefore assume without deciding that the second interrogation took place under circumstances
amounting to Miranda custody.
6
II. Factual Background

On May 28, 2021, a Tarrant County grand jury charged Morenocastaneda with

continuous family violence against a person he was dating, Yanes, by acts including scratching

her, grabbing her, and pouring gasoline on her. Morenocastaneda was released on bond. Yanes

paid Morenocastaneda’s bail. On February 22, 2022, Morenocastaneda pled nolo contendre to

the lesser-included offense of assault causing bodily injury to a family member. The trial court

placed Morenocastaneda on deferred adjudication community supervision. One of the conditions

of his supervision was that he was not to contact Yanes “in any manner (directly or indirectly).”

At around 4 a.m. on October 30, 2022, a Tarrant County man returned home from a night

out with friends to find an unfamiliar car in front of his house, and next to it, a dead woman. He

called the police. The woman was Yanes. The autopsy revealed bruises all over Yanes’s body,

broken bones in her face, and evidence of fatal blow(s) to the back of her head with a heavy

blunt object. The investigation by the Arlington Police Department (APD) did not turn up

security footage of the crime being committed. But the investigation did discover security

footage placing Morenocastaneda and Yanes together in an Arlington grocery store on the

evening of October 29, 2022. Morenocastaneda could not be found at the work address he had

given to his community-supervision officer. Morenocastaneda did not show up for a scheduled

meeting with his community-supervision officer. The APD held a press conference to solicit the

public’s help in locating Morenocastaneda. Tips from the public led to the December 1, 2022,

arrest of Morenocastaneda. At that time, Morenocastaneda was arrested for violating his

conditions of community supervision.

7
The first interrogation took place at the APD in conjunction with his December 1, 2022,

arrest. The investigating officers told Morenocastaneda that Yanes was dead. The officers told

Morenocastaneda they wanted his help in identifying who killed Yanes. Officers then warned

him pursuant to Miranda. Morenocastaneda asked to speak to an attorney. The interrogation

went no further. As a result, the interrogating officers did not reveal what the investigation had

uncovered up to that date. Nonetheless, the stakes of the first interrogation were plain and high.

As stated by Morenocastaneda at the hearing on his motion to suppress, “[Officers told] him that

his ex [wa]s dead. So he [knew they were] talking about an allegation of murder.”

Between the first interrogation and the second interrogation, Morenocastaneda was never

a free man. Following the first interrogation, Morenocastaneda was transferred to the Tarrant

County Jail, where he remained until the hearing on the State’s motion to adjudicate regarding

the bodily injury to a family member charge. During the months spent in the Tarrant County Jail

awaiting adjudication, Morenocastaneda was not questioned about the death of Yanes. Nor was

he provided counsel specifically regarding the murder charge; there was no murder charge at that

time. Morenocastaneda was appointed counsel regarding the State’s motion to adjudicate.

Eventually, Morenocastaneda pled true to violating the terms of his community supervision. At

the July 6, 2023, adjudication hearing, the trial court sentenced him to 200 days in jail and gave

him credit for the 243 days of jail time he had served. In other words, Morenocastaneda had

completed that sentence.

While in the Tarrant County Jail, Morenocastaneda was subject to an immigration

detainer that was placed on him by the United States Immigration and Customs Enforcement

8
(ICE) agency. The detainer was placed at the time of Morenocastaneda’s arrest for violating the

terms of his community supervision. As a result, on July 7, 2023, Morenocasteneda was

transferred to an ICE detention facility almost an hour’s drive away.

The second interrogation occurred thirteen days later on July 20, 2023. From December

2022 to July 2023, the APD investigation regarding Yanes’s murder had been ongoing. Among

other things, DNA obtained from the vehicle at the crime scene was sent off for testing. When

the DNA results came back, they indicated that Morenocastaneda had been in that vehicle. For

that and other reasons, the APD obtained a warrant for Morenocastaneda’s arrest for the murder

of Yanes. On July 19, 2023, officers with the APD retrieved Morenocastaneda from the ICE

detention center and brought him to the APD facility. The interrogating officers provided

Morenocastaneda Miranda warnings regarding his rights. Morenocastaneda said that he

remembered those warnings from the first interrogation. However, during this second

interrogation, he did not ask for an attorney. The interrogation proceeded. Ultimately,

Morenocastaneda confessed to striking Yanes in the head with a pipe.

III. Arguments of the Parties

During the pre-trial stage of the murder case, Morenocastaneda moved to suppress his

confession. He contended that his request to speak to an attorney from the first interrogation

should result in the exclusion of anything said during the second interrogation.14

14
During trial, Morenocastaneda asserted that the second interrogation was involuntary and coercive in its own right.
He does not make that assertion on appeal. See Berghuis v. Thompkins, 560 U.S. 370, 385 (2010) (“Although
Miranda imposes on the police a rule that is both formalistic and practical when it prevents them from interrogating
suspects without first providing them with a Miranda warning, . . . it does not impose a formalistic waiver procedure
that a suspect must follow to relinquish those rights. As a general proposition, the law can presume that an
individual who, with a full understanding of his or her rights, acts in a manner inconsistent with their exercise has
9
Morenocastaneda contended in the trial court, and contends here, that the Edwards rule should

apply, and that there was no Shatzer “break in custody” between the first interrogation and the

second. Morenocastaneda contends that while in the Tarrant County Jail awaiting adjudication

on the family violence charge, he was in the custody of the same authorities pursuing the

looming murder charge against him. Morenocastaneda contends that at the time of the second

interrogation, he was expressly being held on the charge he was first interrogated for, the murder

of Yanes. He contends that he never returned to a state of normalcy following the first

interrogation. Among other things, he points out that he is from Mexico, as are his friends and

family (at least those he is close to). He complains of “bad[]” and “ugly” food in the ICE

detention facility. He complains that the second interrogation was conducted shortly after a

disruptive transfer from the ICE detention facility to the APD facility. Morenocastaneda

contends these circumstances fit squarely within Edwards and fall outside of Shatzer.

The State contends that there was a “break in custody” within the meaning of Shatzer.

Specifically, the State contends that “the passage of time while Appellant waited in jail for the

disposition of the motion to revoke his probation counted toward the fourteen days.” The State

contends that “because Shatzer established a bright-line rule . . . no other factors must be

considered by a court in determining whether there is a sufficient break in custody.”

IV. Standard of Review

The standard of review regarding motions to suppress is established. “We review a trial

court’s ruling on a motion to suppress using a bifurcated standard for an abuse of discretion.”

made a deliberate choice to relinquish the protection those rights afford.” (citation omitted)); Leza v. State, 351
S.W.3d 344, 349 (Tex. Crim. App. 2011).
10
State v. Espinosa, 666 S.W.3d 659, 667 (Tex. Crim. App. 2023). “We defer to a trial court’s

findings of fact that are supported by the record.” Id. “We review de novo legal questions and

mixed questions that do not turn on credibility and demeanor . . . .” Id.15 “The evidence and all

reasonable inferences are viewed in the light most favorable to the trial court’s ruling, and the

trial court’s ruling must be upheld if it is reasonably supported by the record and is correct under

a theory of law applicable to the case.” Id.

The bifurcated review process applies in the Miranda context. Pecina, 361 S.W.3d at

78–79 (“In reviewing claims concerning Miranda violations and the admission of statements

made as the result of custodial interrogation, we conduct [a] bifurcated review . . . .”).

When a trial court denies a motion to suppress and does not enter findings
of fact, we view the evidence in the light most favorable to the ruling and assume
the trial court made implicit findings of fact that support its ruling as long as those
findings are supported by the record.

Wexler v. State, 625 S.W.3d 162, 167 (Tex. Crim. App. 2021). “The party that prevailed in the

trial court is afforded the strongest legitimate view of the evidence, and all reasonable inferences

that may be drawn from that evidence.” Id.

Videographic evidence can present questions of credibility and demeanor. State v.

Duran, 396 S.W.3d 563, 570–71 (Tex. Crim. App. 2013); Tucker v. State, 369 S.W.3d 179, 185

(Tex. Crim. App. 2012) (“The court of appeals should view the video in the light most favorable

to the trial court’s ruling and assume that the trial court made implicit findings that support the

denial of Appellant’s motion to suppress.”).

15
Espinosa involved review of a trial court’s probable cause ruling. Espinosa, 666 S.W.3d at 667. “Whether
probable cause existed is a mixed question of law and fact that does not turn on credibility and demeanor.” Id. at
669. Consequently, “[o]n appeal, a finding of probable cause is reviewed de novo.” Id.
11
V. Analysis

We find no abuse of discretion in the trial court’s denial of the motion to suppress.

Transcripts and video recordings from both interrogations were before the trial court for

purposes of Morenocastaneda’s motion to suppress. The trial court stated, on the record, that it

reviewed both videos. While no live witnesses were called at the hearing on Morenocastaneda’s

motion to suppress, the trial court had evidence before it regarding Morenocastaneda’s

experiences between the first and second interrogations. That evidence came from

Moreneocastaneda himself during the second interrogation. Among other things,

Morenocastaneda stated that he had been crying alone while in jail, unable to find peace. Instead

of asserting that he was coerced into a confession, Morenocastaneda stated that he thought that

“if they brought [him] [t]here [he] was going to tell the truth.” Morenocastaneda argues that he

was never able to return to normalcy as he knew it before December 1, 2022. It is undisputed

that he was not bailed out this time, and that while he had some siblings in Texas, his close

family members were in Mexico. But Morenocastaneda does not attribute those facts to acts of

the State. In any event, during the second interrogation, Morenocastaneda discussed his life

before December 1, 2022.

Morenocastaneda’s first interrogation involved the same police department.

Consequently, the video recording of Morenocastaneda’s first interrogation provides context for

the trial court’s weighing of the testimony and credibility of the second interrogation. As

additional context, the same trial court, the 372nd Judicial District Court of Tarrant County,

presided over both the family violence case and the murder case. “The reason that reviewing

12
courts defer to the trial court’s factual determinations is precisely because the judge is ‘Johnny-

on-the-spot,’ personally able to see and hear the witnesses testify.” Mays v. State, 476 S.W.3d

454, 459 (Tex. Crim. App. 2015) (quoting Manzi v. State, 88 S.W.3d 240, 254 (Tex. Crim. App.

2002) (Cochran, J., concurring)).

Accordingly, we defer to the trial court’s assessment of whether Morenocastaneda’s time

spent in the Tarrant County Jail constituted a Shatzer “break in [Miranda] custody” between the

interrogations in the APD stationhouse.

The trial court was provided Shatzer at the hearing on Morenocastaneda’s motion to

suppress. While the parties present arguments on appeal regarding Edwards and Shatzer, neither

side contends that the trial court relied on the wrong legal rule when denying Morenocastaneda’s

motion to suppress. Rather, it appears that the parties, on appeal, are inviting this Court to

decide the matter de novo based on additional legal authorities not provided to the trial court.

We decline to decide the matter de novo.

We do, however, reject two legal contentions presented by the parties.

Morenocastaneda asserts that “his period in custody from December 2022 to July 2023

(until he was transferred to ICE), cannot show a break in custody.” Morenocastaneda cites no

case establishing, as a rule of law, that the time spent in a county jail can never serve as a break

from Miranda custody at a police stationhouse. Morenocastaneda cites cases supporting his

argument that, in his circumstance, his time spent in jail should not count under Shatzer. But

“should not” is different from “can never.” For example, the Supreme Court in Shatzer itself

spoke of “the vast differences between Miranda custody and incarceration pursuant to

13
conviction.” Shatzer, 559 U.S. at 114 (emphasis added). Morenocastaneda reasons that he was

in jail, not serving a post-conviction prison sentence, and that difference should legally control

the outcome of his case. Likewise, Morenocastaneda points to Shatzer’s discussion of “the

paradigm Edwards case. That is a case in which the suspect ha[d] been arrested for a particular

crime and [wa]s held in uninterrupted pretrial custody while that crime [wa]s being actively

investigated.” Id. at 106 (emphasis added). Morenocastaneda’s situation is not “the paradigm

Edwards case.” See id. But it is close: Morenocastaneda was not in the Tarrant County Jail on a

murder charge. He was in jail for months awaiting adjudication on a family violence charge

regarding the murder victim.

Shatzer observed, “Sentenced prisoners, in contrast to the Miranda paradigm, are not

isolated with their accusers. They live among other inmates, guards, and workers, and often can

receive visitors and communicate with people on the outside by mail or telephone.” Id. at 113.

A Tarrant County district judge would be in the better position to know whether, under the

circumstances of Morenocastaneda’s case, the Tarrant County Jail offered conditions more akin

to incarceration, at least for Miranda custody purposes. Contrary to Morenocastaneda’s position

that this is susceptible to resolution as a question of law, Herrera held, under the circumstances

of that case, that a defendant could be interrogated in jail regarding a different matter without

presenting the risks of coercion amounting to Miranda custody. See Herrera, 241 S.W.3d at

522, 531. Here, Morenocastaneda was not interrogated during his months in the Tarrant County

Jail. If Morenocastaneda’s time spent in the Tarrant County Jail did not rise to the level of

14
Miranda custody under the fact-based Herrera decision, then it would be a break in Miranda

custody for Shatzer purposes. The trial court implicitly found that such a break occurred.

The State asserts that the passage of more than fourteen days is all that is needed to be

considered under Shatzer. That too misses the mark. Whether there has been a break in

Miranda custody needs to be determined before counting off the days. Shatzer, 559 U.S. at 110

(“If Shatzer’s return to the general prison population qualified as a break in custody, . . . there is

no doubt that it lasted long enough (two years) to meet that durational requirement.” (emphasis

added)). Notably, Shatzer did not get into the weeds of determining where, exactly, within that

longer timespan the fourteen days began and ended. See id. We follow Shatzer’s example.

In Pecina, the Texas Court of Criminal Appeals recounted Justice Jackson’s warning that

the Supreme Court “is forever adding new stories to the temples of constitutional law, and the

temples have a way of collapsing when one story too many is added.” Pecina, 361 S.W.3d at 74

(quoting Montejo v. Louisiana, 556 U.S. 778, 799 (2009) (quoting Douglas v. City of Jeannette,

319 U.S. 157, 181 (1943))). In light of that, we decline to decide this case as a matter of law as

though the Supreme Court or the Texas Court of Criminal Appeals has added additional floors

on top of the three-story Miranda-Edwards-Shatzer structure or locked the door to a room on the

Shatzer floor.

Given the deferential standard of review set forth above, we consider the trial court’s

denial of the motion to suppress as a ruling that the State established factually, and by a

preponderance of the evidence, that there was a break in Miranda custody that satisfied Shatzer

15
and thereby overcame the Edwards presumption. We find the trial court’s ruling to be

reasonably supported by the record and correct under a theory of law applicable to the case.

VI. Conclusion

We affirm the judgment of the trial court.

Jeff Rambin
Justice

Date Submitted: November 10, 2025
Date Decided: June 12, 2026

Do Not Publish

16

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