Two Hours Between Warrantless Arrest and a Confession
In Self v. State, 709 S.W.2d 662, 665-66 (Tex. Crim. App. 1986), the defendant received Miranda warnings three times before giving his confession, and the warnings were also on the statement he read, corrected, and signed. 709 S.W.2d at 666.
Two hours elapsed between the arrest and the confession. Id.
After the Miranda warnings, there were no intervening circumstances. Id.
The defendant was not taken before a magistrate, and it did not appear that the officers obtained an arrest warrant before the confession. Id.
There was, however, probable cause for the warrantless arrest, and there was nothing to indicate that the defendant's arrest was violent or designed to cause surprise, fright, and confusion. Self, 709 S.W.2d at 667-68.