Medrano v. Texas

Issues: (1) Whether under all the circumstances — including an officer’s knowing and deliberate deployment of Rodolfo Medrano’s wife to elicit statements from him while he was in custody, the falsity of the information the officer gave her to convey to him, the strength of the incentive the officer proffered to induce him to speak, and the fact that similar tactics were deliberately employed to obtain confessions from codefendants — introduction of the resulting statement violated Medrano’s Fifth and 14th Amendment rights under Miranda v. Arizona; and (2) whether the Texas Court of Criminal Appeals’s determination that Medrano's subsequent petition failed to satisfy the requirements of Texas Code of Criminal Procedure Article 11.071(5)(a)(2) was an adequate and independent state ground precluding merits review of his claim, where that provision authorizes a subsequent petition when “by a preponderance of the evidence, but for a violation of the United States Constitution no rational juror could have found the applicant guilty beyond a reasonable doubt” and the confession whose constitutionality Medrano is challenging was the only significant evidence linking him to the capital murder with which he was charged.