Nguyen v. State
The trial court should have suppressed the defendant's oral statement claiming that he owned his friend's drugs when the investigating officer failed to warn the defendant of all of his rights under CCP art. 38.22 ยง3 during a traffic stop and roadside interrogation. There is no statutory exception in art. 38.22 for statements that constitute a crime committed after law enforcement officials violated that provision in attempting to obtain evidence of a previously committed crime. The Court rejects the State's argument that art. 38.23 requires that evidence of a crime committed before illegal conduct be suppressed, but evidence of a crime committed after the illegal conduct is not subject to suppression.
