## Facts

- Lynn Palmer and Mary Dabney were approached in a parking lot; Palmer was stabbed and Dabney was threatened with a knife and robbed of her purse.
- Palmer died from the stabbing.
- Dabney described the assailant as a young Latin male but could not later make a positive in-court identification of Michael Vasquez.
- Restaurant employees told police the description matched Vasquez, a former busboy, and reported he had been at the restaurant shortly before the offense.
- Police took Vasquez, then a juvenile, into custody without a warrant under Texas Family Code § 52.01; he later was certified to stand trial as an adult.
- After the detention, police obtained Vasquez’s confession and a monogrammed cigarette lighter belonging to the victim.
- Vasquez was tried for capital murder, convicted, and sentenced to mandatory life imprisonment.

## Issues

1. Whether a warrantless taking of a juvenile into custody under Texas Family Code § 52.01 becomes unlawful when the juvenile is later certified and prosecuted as an adult, such that adult arrest limits in Texas Code of Criminal Procedure chapter 14 must govern.
2. Whether the detention and resulting confession and physical evidence were inadmissible as fruits of an illegal seizure under the Fourth Amendment and Texas law.
3. Whether applying § 52.01 to a later-certified juvenile denies equal protection under the Fourteenth Amendment and Texas Constitution by providing fewer arrest protections than adults receive.

## Decision

- The Texas Court of Criminal Appeals (en banc) affirmed the conviction and life sentence.
- The court held that § 52.01 validly authorized the warrantless taking of Vasquez into custody as a juvenile, and the legality of the seizure is judged at the time it occurred.
- The court concluded police had probable cause based on reasonably trustworthy information connecting Vasquez to the offense.
- Because the detention was lawful, the confession and cigarette lighter were not suppressible as fruits of an illegal arrest.
- The court rejected the equal-protection challenge, finding the juvenile–adult distinction a reasonable legislative classification.

## Legal Principles

- Juvenile delinquency proceedings are treated as civil in nature, and the Texas Code of Criminal Procedure does not govern juvenile-court matters unless the Legislature clearly provides otherwise.
- A juvenile may be taken into custody without a warrant under Texas Family Code § 52.01 if supported by probable cause.
- Probable cause exists when, at the moment of seizure, the officer’s knowledge based on reasonably trustworthy information would warrant a reasonable and prudent person to believe the suspect committed or is committing an offense.
- Later certification and adult prosecution do not retroactively convert a lawful juvenile detention into an unlawful adult arrest measured by chapter 14 requirements.
- Equal protection is not violated by different treatment of juveniles and adults where the classification is reasonable and substantial and the groups are not similarly situated for the challenged purpose.

## Conclusion

The court held that a juvenile’s warrantless detention under Texas Family Code § 52.01 is valid if supported by probable cause, and later certification to stand trial as an adult does not impose adult arrest restrictions retroactively; consequently, evidence obtained after the lawful detention was admissible and the equal-protection challenge failed.


Vasquez v. State, 739 S.W.2d 37 (Tex. Crim. App. 1987)