The State of Texas v. Cory A. Stevens, Appellee

Summary

The Court of Criminal Appeals held that the court of appeals erred in applying an 'almost total deference' standard to the Brazoria County trial court's ruling granting suppression on collateral estoppel grounds, because that ruling involved no witness testimony, no credibility determinations, and no findings of historical facts. A trial court's decision to apply collateral estoppel is a question of law applied to the facts, and where, as here, it rests on no credibility or demeanor evaluations, de novo review is required. The Court reversed and remanded to the court of appeals for reconsideration. Judge Cochran, joined by Judges Keasler and Hervey, concurred to caution that the Court did not hold—and she does not necessarily accept—that collateral estoppel actually applies to pretrial suppression rulings.