LAW.coLAW.co

Steve O'Neal Green v. the State of Texas

2026-08-27

Summary

Holding. The court affirmed the trial court's judgment, holding that the backpack search was constitutional as a search incident to arrest, the article 38.23 jury instruction was properly denied because no disputed factual issue was presented to the jury, and the admission of extraneous offense evidence during the punishment phase did not constitute reversible error.

Green was convicted of possessing a controlled substance and received a ten-year prison sentence. On appeal, he challenged the trial court's denial of his motion to suppress evidence obtained from a warrantless search of his backpack at the jail, the exclusion of a jury instruction regarding statutory protections against illegally obtained evidence, and the admission of evidence concerning an unadjudicated attempted sexual assault offense during the punishment phase. Green argued the backpack search was unconstitutional and invited the court to extend Supreme Court precedent governing vehicle searches to personal property. He also contended that factual disputes existed regarding the validity of the municipal warrants used to arrest him and that prejudicial evidence of an old, dissimilar offense unfairly influenced the jury's sentencing recommendation.

The court examined each challenge and found no error. Regarding the backpack search, the court held that because Green was arrested lawfully on valid warrants, the search of his backpack incident to arrest was justified as a search of property on the arrestee's person without requiring further justification. Regarding the jury instruction request, the court determined that Green failed to present affirmative evidence of a disputed fact about warrant validity before the jury and noted that even if the warrants had been invalid, the good-faith exception to suppression would have applied. Regarding the extraneous offense evidence, the court determined it was relevant to punishment and that any potential error under evidentiary rules was harmless given Green's extensive criminal history and the limited reference made to the unadjudicated offense.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a warrantless search of an arrestee's backpack conducted at jail is constitutional as a search incident to arrest
  • Whether the trial court was required to instruct the jury on statutory protections against illegally obtained evidence when the defendant failed to affirmatively contest disputed facts before the jury
  • Whether admission of evidence regarding an unadjudicated attempted sexual assault offense during the punishment phase violated statutory and evidentiary rules

Procedural posture

Green appealed his conviction and ten-year sentence from the 272nd District Court of Brazos County, challenging the trial court's evidentiary rulings and jury instruction decisions.

Authorities cited

Opinion

majority opinion

Court of Appeals

Tenth Appellate District of Texas

10-25-00147-CR

Steve O'Neal Green,

Appellant

v.

The State of Texas,

Appellee

On appeal from the

272nd District Court of Brazos County, Texas

Judge John L. Brick, presiding

Trial Court Cause No. 23-04189-CRF-272

JUSTICE SMITH delivered the opinion of the Court.

MEMORANDUM OPINION

After a jury trial, Green was convicted of possession of a controlled

substance in an amount of less than one gram. See TEX. HEALTH & SAFETY

CODE ANN. § 481.115(b). He pled “true” to two felony enhancement paragraphs,

and the jury assessed his punishment at ten years in prison. On appeal, Green

challenges the trial court’s denial of his motion to suppress evidence, exclusion

of his requested jury instruction, and admission of certain extraneous-offense

evidence in the punishment phase. We affirm.

Motion to Suppress

Green claims in his first issue that the trial court reversibly erred by

denying his motion to suppress the evidence seized from a warrantless search

of his backpack at the jail. He invites us to extend the principles of Arizona v.

Gant beyond warrantless vehicle searches to the search of his backpack and

contends that the search cannot be justified as a search incident to arrest.1 556

U.S. 332 (2009). We disagree.

STANDARD OF REVIEW

When reviewing a trial court’s ruling on a motion to suppress, we apply

a bifurcated standard of review. State v. Rodriguez, 521 S.W.3d 1, 8 (Tex.

Crim. App. 2017). We give almost complete deference to the trial court’s

determination of historical facts. Id. We then proceed to a de novo

determination of “the legal significance of the facts as found by the trial court—

including the determination of whether a specific search or seizure was

reasonable.” Id. We view all the evidence in the light most favorable to the

trial court’s ruling. State v. Garcia-Cantu, 253 S.W.3d 236, 241 (Tex. Crim.

App. 2008).

1 Green also contends that the search cannot be justified as an inventory search. We need not address this contention based on our disposition of this issue. See TEX. R. APP. P. 47.1.

Steve O'Neal Green v. The State of Texas Page 2 RELEVANT BACKGROUND

Green’s pre-trial motion to suppress evidence ran with the trial.

Evidence presented during the State’s case-in-chief established that officers

observed Green violating the Transportation Code by operating a bicycle at

night that was not equipped with a front lamp. TEX. TRANS. CODE ANN. §

551.104(b)(1). Green was wearing a backpack. During the stop, officers had

Green sit on the curb while they contacted dispatch with his identifying

information. Dispatch informed officers that Green might have several

municipal warrants for his arrest. While waiting for confirmation that the

warrants were active, officers placed Green in handcuffs. After intake

personnel with the police department confirmed the warrants were active,

officers arrested Green and put him in the back of the patrol vehicle.

An officer began searching Green’s backpack and placing its contents on

the hood of the patrol vehicle. However, due to darkness and the presence of

“adult toys and entertainment paraphernalia,” the officer stopped his search,

secured the backpack in the patrol car, and transported Green to jail. While

Green was getting booked in, the officer continued searching the backpack. In

an external pocket, the officer located an empty chip bag containing several

small white rocks that eventually tested positive for the presence of cocaine.

Steve O'Neal Green v. The State of Texas Page 3

After the State rested, outside of the jury’s presence, the trial court heard

counsel’s arguments on the motion to suppress.2 The trial court found that

“the search incident to arrest was valid” and denied the motion.

ANALYSIS

The Supreme Court has identified two distinct categories within the

search-incident-to-arrest exception to the warrant requirement. United States

v. Robinson, 414 U.S. 218, 224 (1973). The first category is a search of the

arrestee’s person, which extends to property immediately associated with the

person of the arrestee.3 United States v. Chadwick, 433 U.S. 1, 14-15 (1977).

If a search falls under this category, a lawful custodial arrest is the sole

justification needed to perform the search. Id.

The second category is a search of the area within the arrestee’s

immediate control. Robinson, 414 U.S. at 224. A search pursuant to this

category must be limited to “the area from within which [the arrestee] might

2 The State initially contends on appeal that Green forfeited any error in the trial court’s denial of his

motion to suppress by failing to obtain a ruling on the motion until after the trial court admitted the contested evidence, and affirmatively stating “no objection” to its admission. However, the Court of Criminal Appeals has held:

If the record as a whole plainly demonstrates that the defendant did not intend, nor

did the trial court construe, his “no objection” statement to constitute an abandonment

of a claim of error that he had earlier preserved for appeal, then the appellate court

should not regard the claim as “waived,” but should resolve it on the merits.

Thomas v. State, 408 S.W.3d 877, 884-85 (Tex. Crim. App. 2013). We find that the record as a whole plainly demonstrates no waiver or abandonment by Green, particularly considering the trial court’s decision to take up the motion to suppress after the statement of “no objection.” See Bouyer v. State, 264 S.W.3d 265, 268 (Tex. App.—San Antonio 2008, no pet.).

3

But see, Riley v. California, 573 U.S. 373 (2014) (does not extend to digital data on cell phones or similar devices).

Steve O'Neal Green v. The State of Texas Page 4 gain possession of a weapon or destructible evidence.” Chimel v. California,

395 U.S. 752, 763 (1969). Gant addressed this category in the context of vehicle

searches. 556 U.S. at 335. The Court held that police may search a vehicle

incident to arrest “only if the arrestee is within reaching distance of the

passenger compartment at the time of the search or it is reasonable to believe

the vehicle contains evidence of the offense of arrest.” Id. at 351.

Green argues that if we extend Gant beyond warrantless vehicle

searches, then the backpack search at the jail was unconstitutional because

any concern for officer safety or evidence destruction had dissipated. Gant,

however, carefully limited its holding to the second category of searches in the

context of automobiles. We decline Green’s invitation to extend Gant to

searches of personal effects in the arrestee’s possession at the time of arrest.

We find that this search incident to arrest falls under the first Robinson

category, and the only required justification for the search was a lawful arrest.

This finding aligns with the Court of Criminal Appeals’s recent statement in

Price v. State, that where

an arrestee is in actual possession of a receptacle at the time of, or

reasonably contemporaneously to, his custodial arrest, and that

receptacle must inevitably accompany him into custody, a

warrantless search of that receptacle at or near the time of the

arrest is reasonable under the Fourth Amendment as a search

incident to the arrestee’s person. Such a search requires no greater

justification than the fact of the lawful arrest itself.

Steve O'Neal Green v. The State of Texas Page 5

662 S.W.3d 428, 438 (Tex. Crim. App. 2020) (plurality op.).

Because Green’s lawful arrest supports the search of his backpack as a

search incident to arrest, the trial court did not err in denying his motion to

suppress.4 Accordingly, we overrule Green’s first issue on appeal.

Article 38.23 Jury Instruction

Green contends in his second issue that the trial court reversibly erred

by denying his requested article 38.23 jury instruction. See TEX. CODE CRIM.

PROC. ANN. art. 38.23(a). He argues that the instruction should have been

included so that the jury could resolve a factual dispute about “the validity of

the collection warrants on which [he] was arrested.” We disagree.

STANDARD OF REVIEW AND RELEVANT LAW

Article 38.23 of the Code of Criminal Procedure provides that no

evidence obtained by an officer in violation of the laws of Texas or the

United States shall be admitted in evidence against an accused on the trial of

any criminal case. See id. Where the evidence raises this issue, the jury shall

be instructed that if it believes, or has a reasonable doubt, that the evidence

was obtained in violation of the law, it shall disregard the evidence

obtained. See id.

4 Green does not attack the lawfulness of his arrest on the municipal warrants in this issue, though

he contends in his second issue that there was a factual dispute as to their validity. We resolve Green’s second issue against him below.

Steve O'Neal Green v. The State of Texas Page 6

A defendant's right to an article 38.23(a) jury instruction is limited to

disputed issues of fact that are material to his claim of a constitutional or

statutory violation that would render evidence inadmissible. Madden v. State,

242 S.W.3d 504, 509-10 (Tex. Crim. App. 2007). There are three requirements

that must be met to be entitled to an instruction pursuant to article 38.23(a):

(1) the evidence heard by the jury must raise an issue of fact; (2) the evidence

on that fact must be affirmatively contested; and (3) that contested factual

issue must be material to the lawfulness of the challenged conduct in obtaining

the evidence. Id. at 510.

To raise a disputed fact issue warranting an article 38.23 jury

instruction, there must be some affirmative evidence that puts the existence of

that fact into question. Id. at 513. Mere insinuations by a defendant’s attorney

on cross examination do not raise a fact issue. See Garza v. State, 126 S.W.3d

79, 87 (Tex. Crim. App. 2004). If there is no disputed factual issue, the legality

of the conduct is determined by the trial judge alone as a question of

law. Madden, 242 S.W.3d at 510.

RELEVANT BACKGROUND

The five municipal warrants on which Green was arrested were issued

on January 22, 2019. Certified copies of each capias pro fine were admitted

into evidence as State’s Exhibits 9 through 13. On each of the State’s exhibits,

Steve O'Neal Green v. The State of Texas Page 7

the officer’s return was completed and dated August 2, 2023 – the date of

Green’s arrest in this case. The trial court found that these warrants were

valid.

The trial court also admitted Defendant’s Exhibits 10 through 13 into

evidence. Defendant’s Exhibits 10, 11, and 13 are capias pro fine warrants

issued on August 31, 2023, in the same cause numbers as State’s Exhibits 9,

11 and 13, respectively, though they list a different amount due than the

State’s corresponding exhibits. Defendant’s Exhibit 12 appears to be a

duplicate copy of State’s Exhibit 9, except that the officer’s return is not

completed. There does not appear to be a corresponding defendant’s exhibit to

State’s Exhibit 10.5

ANALYSIS

On appeal, Green asserts that his requested article 38.23 jury

instruction was warranted because “a material, contested fact issue existed on

the validity of the collection warrants” on which he was arrested; namely, the

possibility of a “clerical error in failing to recall collection warrants that had

been laid out or otherwise satisfied[.]” The State responds that Green failed to

5 When the trial court overruled Green’s requested 38.23 jury instruction during the charge conference,

Green submitted a written proposed jury charge including his requested instruction.

Steve O'Neal Green v. The State of Texas Page 8 affirmatively contest this factual dispute in front of the jury. We agree with

the State.

Simply offering Defendant’s Exhibits 10 through 13 into evidence was

insufficient on its own to create a factual dispute. See Sterling v. State, 10-19-00250-CR, 2020 WL 950147, *2-3 (Tex. App.—Waco Feb. 26 2020, pet. ref’d)

(mem. op., not designated for publication) (citing Madden, 242 S.W.3d at 513-16). As noted by the State, Green “never elicited testimony regarding whether

the warrants in State’s Exhibits 9 through 13 were recalled or satisfied[.]”

Though Green argued his clerical-error theory to the court outside of the jury’s

presence, Green did not affirmatively contest the validity of the warrants on

which he was arrested in front of the jury. Because Green failed to present

affirmative evidence of a factual issue for the jury to resolve, the trial court did

not err in refusing the article 38.23 instruction.

Moreover, even assuming, arguendo, that all of the warrants on which

Green was arrested were recalled or otherwise satisfied, the good-faith

exception negated his requested instruction. See TEX. CODE CRIM. PROC. ANN.

art. 38.23(b). Green does not contest the facial validity of the warrants in

State’s Exhibits 9 through 12; however, he argues that the article 38.23 goodfaith exception does not apply to his capias pro fine warrants because those

Steve O'Neal Green v. The State of Texas Page 9

warrants are not based on probable cause. Contrary to Green’s contention, the

Court of Criminal Appeals has explained:

While a capias is issued after a judgment has been rendered

against the defendant, it must still be supported by probable cause.

But because a judgment against a defendant signifies a finding

beyond a reasonable doubt that he has committed the charged

offense, we have held in the context of a parole violation that a

judgment coupled with a finding by the court that there is a

“reason to believe” that the defendant has violated the conditions

of his parole will constitute sufficient probable cause to support the

issuance of a parole violation warrant. While a traffic violator,

unlike a parolee, is not subject to a judgment imposing a term of

imprisonment, the judgment establishing the traffic violation

nonetheless carries considerable weight and validity because it is

based upon a finding beyond a reasonable doubt. Thus, a

judgment for a traffic violation, together with a finding by the court

that the defendant has failed to satisfy its terms, will comprise

sufficient probable cause to support issuance of the capias pro fine.

Jones v. State, 119 S.W.3d 766, 786 (Tex. Crim. App. 2003); see Durio v. State,

807 S.W.2d 876 (Tex. App.—Corpus Christi-Edinburg 1991, no pet.) (holding

that the good-faith exception applied to evidence seized by officers acting in

good-faith reliance on facially valid municipal warrants, even where the

warrants were later determined to be invalid). We overrule Green’s second

issue.

Extraneous Offense Evidence

In his third issue, Green claims that the trial court reversibly erred by

overruling his article 37.07 and Rule 403 objections to State’s Exhibits 31 and

Steve O'Neal Green v. The State of Texas Page 10

33 during the punishment phase of trial. See TEX. CODE CRIM. PROC. ANN. art.

37.07; TEX. R. EVID. 403. We disagree.

ANALYSIS

We review a trial court’s decision to admit extraneous offense evidence

for an abuse of discretion. Mitchell v. State, 931 S.W.2d 950, 953 (Tex. Crim.

App. 1996).

State’s Exhibit 33 is a certified copy of an indictment alleging that Green

committed the offense of attempted sexual assault on or about February 11,

2005.

State’s Exhibit 31 is a certified copy of a document requesting the trial

court to take into consideration the unadjudicated attempted sexual assault

offense in assessing Green’s punishment for the offense of injury to a child.

The document includes a statement that the trial court, having heard Green

“admit his guilt” to the attempted sexual assault, barred further prosecution

of the offense and released him from the charge.

Article 37.07

If the trial court deems it relevant to sentencing, the State may introduce

evidence of an extraneous bad act that is shown beyond a reasonable doubt to

have been committed by the defendant, regardless of whether he has

Steve O'Neal Green v. The State of Texas Page 11

previously been charged with or finally convicted of the act. See TEX. CODE

CRIM. PROC. ANN. art. 37.07, § 3(a)(1).

At trial, Green argued that State’s Exhibits 31 and 33 were “mere

accusations” and were inadmissible under article 37.07 unless supported by

testimony proving the unadjudicated attempted sexual assault beyond a

reasonable doubt. On appeal, he contends that the trial court should not have

treated the exhibits as a judicial confession and should have required

additional testimonial proof of the unadjudicated offense before admitting the

documents into evidence. As to this argument, we note that the beyond-areasonable-doubt burden in the punishment phase applies to the defendant's

involvement in the extraneous act itself – in other words, whether the

extraneous act is attributable to him – not to the elements of a crime necessary

for a finding of guilt. Haley v. State, 173 S.W.3d 510, 515 (Tex. Crim. App.

2005).

Relevance in the punishment phase is “a question of what is helpful to

the jury in determining the appropriate sentence for a particular defendant in

a particular case.” Rogers v. State, 991 S.W.2d 263, 265 (Tex. Crim. App. 1999).

The trial court is the exclusive authority on the threshold issue of admissibility

of relevant evidence, while the jury ultimately determines whether the State

has met the burden of proof for the extraneous act. Mitchell, 931 S.W.2d at

Steve O'Neal Green v. The State of Texas Page 12

954. “Stated differently, the trial court is not charged with determining

whether the State has proven the extraneous offenses beyond a reasonable

doubt” in deciding whether to admit the evidence. Nanez v. State, 179 S.W.3d

149, 152-53 (Tex. App.—Amarillo 2005, no pet.).

Here, the trial court found that the unadjudicated attempted sexual

assault evidence was relevant for punishment. A defendant’s history of bad

acts is relevant evidence for a jury to consider when assessing an appropriate

sentence because it relates to the defendant’s character, and the existence of

prior bad acts and crimes may justify the imposition of a harsher sentence for

the charged offense. Ex parte Boxton, 888 S.W.2d 23, 27 (Tex. Crim. App.

1994); see Sanders v. State, 422 S.W.3d 809, 815 (Tex. App.—Fort Worth 2014,

pet. ref’d).

We find that the trial court did not abuse discretion in admitting State’s

Exhibits 31 and 33 under article 37.07.

Rule 403

Even if extraneous evidence is otherwise admissible during the

punishment phase, it may be excludable under Rule 403 if it is substantially

more prejudicial than probative. See TEX. R. EVID. 403.

On appeal, Green claims that State’s Exhibits 31 and 33 were not

probative because the unadjudicated attempted sexual assault is twenty years

Steve O'Neal Green v. The State of Texas Page 13

old and is dissimilar to the possession of a controlled substance offense for

which he was convicted. He also asserts that the evidence suggested

punishment on an improper basis because juries tend to give undue weight to

sexually-based offenses, and he points to the jury’s assessment of the

maximum punishment as support.

Assuming without deciding that the trial court erred in overruling

Green’s Rule 403 objection, we find that the error, if any, was harmless.

Erroneous admission of extraneous offense evidence in the punishment phase

is subject to a non-constitutional harm analysis under Rule 44.2(b) to

determine whether the error affected a substantial right of the defendant. See

TEX. R. APP. P. 44.2(b). Substantial rights are affected when “the error had a

substantial and injurious effect or influence in determining the jury’s verdict.”

Haley, 173 S.W.3d at 518.

Here, the record contains evidence of Green’s extensive criminal history

dating back to 1993, including multiple felony convictions. Though much of

Green’s prior criminal history was theft-related, one of his felony convictions

was for the offense of injury to a child. Green was accused in that case of

subjecting a child to “unreasonable touching.” The trial court in the injury to

a child case also took into consideration the unadjudicated attempted sexual

assault charge in assessing punishment. The judgment reflects that Green’s

Steve O'Neal Green v. The State of Texas Page 14

sentence was initially probated for nine years, but that the trial court

eventually revoked his community supervision and sentenced him to ten years

in prison.

Moreover, in this case, the trial court instructed the jury not to consider

any extraneous bad act or offense unless they believed beyond a reasonable

doubt that Green committed the bad act or offense. There is no indication in

the record that the jury failed to follow this instruction, nor is there any

evidence that Green’s maximum sentence was the result of the unadjudicated

attempted sexual assault. Additionally, the State only briefly mentioned the

unadjudicated attempted sexual assault in its opening statement and in its

closing statement. Each time, the State mentioned the unadjudicated offense

as one piece of Green’s lengthy criminal history in requesting the jury to

consider Green’s “continued pattern of behavior” despite the many

opportunities Green had been given. We find that the trial court’s error, if any,

in overruling Green’s Rule 403 objection was harmless.

Accordingly, we overrule Green’s third issue.

Conclusion

Having overruled all of Green’s issues on appeal, we affirm the trial

court’s judgment.

Steve O'Neal Green v. The State of Texas Page 15

STEVE SMITH

Justice

OPINION DELIVERED and FILED: August 27, 2026

Before Chief Justice Johnson,

Justice Smith, and

Justice Harris

Affirmed

Do Not Publish

CR25

Steve O'Neal Green v. The State of Texas Page 16