In Barefield v. State, 784 S.W.2d 38, 40 (Tex. Crim. App. 1989), a defendant's oral confession was admitted at trial. Id. On appeal, the defendant argued that because he was not asked whether he waived his rights prior to his confession, nor did he expressly waive his rights, his confession should be suppressed. Id. The Texas Court of Criminal Appeals held that the oral confession statute does not require an express verbal waiver and that a waiver of rights may be inferred from the "totality of the circumstances." Id. at 40-41.