Cullen v. State
In Cullen v. State, 195 S.W.3d 696 (Tex. Crim. App. 2006), the Texas Court of Criminal Appeals held that "upon the request of the losing party on a motion to suppress evidence, the trial court . . . must make findings of fact and conclusion of law adequate to provide an appellate court with a basis upon which to review the trial court's application of the law to the facts." Id. at 699.
When ruling on a motion to suppress evidence, a trial court generally makes credibility decisions and factual determinations about disputed historical events.
On appeal, if the trial court had not made findings of fact, the appellate court must "view the evidence in the light most favorable to the trial court's ruling and assume that the trial court made implicit findings of fact that support its ruling as long as those findings are supported by the record." Id. at 698.
In Cullen, the State argued that its right to appeal an order granting a motion to suppress is thwarted when appellate review of the order is based on presumed facts rather than findings of actual facts. Id. at 697.
The court agreed, stating "the trial court's refusal to act prevented the court of appeals from meaningful review of the decision to grant the motion to suppress. Without findings of fact and conclusions of law, the court of appeals was left in the undesirable position of having to make assumptions about the reasons for the trial court's decision." Id. at 698.
In sum, the Texas Court of Criminal Appeals reviewed "whether, upon granting a defendant's motion to suppress evidence, a trial court must grant a timely request for findings of fact." Id. at 696.
The Texas Court of Criminal Appeals created a new "requirement" that a trial court must grant a timely request for findings of fact by the losing party on a motion to suppress evidence. Id. at 699.
This "requirement" was not based on an existing statute or court rule that required findings by the trial court, but rather was created for "the efficient administration of justice." See Cullen, 195 S.W.3d at 699.