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Does the Fifth Amendment’s Self-Incrimination Clause protect a defendant’s refusal to answer law enforcement questioning before he has been arrested or read his Miranda rights? See “Does right to remain silent exist before arrest?” Salinas v. Texas, No. 12-246. Certiorari granted: Jan. 11, 2013. Ruling below: 369 S.W.3d 176 (Tex. Crim. App. 2012).