## Facts

- Jimmie Davis Watson was arrested in connection with an attempted burglary and was jailed.
- While in custody, officers questioned Watson about a different, earlier burglary.
- Officers interrogated Watson four times on the same day, giving Miranda warnings before each session.
- During the earlier interrogation sessions, Watson was largely silent or nonresponsive rather than answering questions.
- In the final session, Watson provided a written inculpatory statement about the earlier burglary.
- The written statement was admitted at Watson’s burglary-of-a-habitation trial, where he was convicted and received an enhanced 25-year sentence.
- On appeal, Watson argued his extended silence amounted to an invocation of the right to remain silent, requiring police to stop questioning and rendering the later statement inadmissible.

## Issues

1. Whether a suspect who has received and understood Miranda warnings invokes the right to remain silent by prolonged silence or nonresponsiveness, absent an explicit request to stop questioning.
2. Whether continued questioning and a later written statement are admissible when the suspect never clearly communicated a desire to terminate interrogation.

## Decision

- The Texas Court of Criminal Appeals affirmed the intermediate appellate court and upheld Watson’s conviction and sentence.
- The court held that, on these facts, Watson’s silence and nonresponsiveness did not constitute an invocation of the right to remain silent.
- Because no invocation occurred, police were not required to stop questioning, and the written statement was admissible.

## Legal Principles

- After Miranda warnings, interrogation must cease only when the suspect indicates, in an objectively understandable manner, a desire to remain silent.
- Mere silence or extended nonresponsiveness, without a reasonably clear communicative act showing a wish to cut off questioning, does not necessarily invoke the right to remain silent.
- Context matters in assessing whether conduct constitutes an invocation, including repeated warnings, the absence of coercion, and the suspect’s later willingness to speak.

## Conclusion

The court concluded that prolonged silence during custodial questioning, without a clear indication that the suspect wished to end the interrogation, did not invoke Miranda’s right to remain silent and did not bar later questioning culminating in an admissible written confession.


Watson v. State, 762 S.W.2d 591 (Tex. Crim. App. 1988)