In a recent case involving a motion to suppress evidence stemming from a traffic stop, a Texas Court of Appeals affirmed the trial court decision, holding that the police officer did not have reasonable suspicion to stop the defendant. The defendant was pulled over after the police officer claimed that the truck crossed the white line into an adjacent lane briefly. At trial, a grand jury returned an indictment charging the defendant with fraudulent possession of identifying information and forgery of a government instrument. The defendant subsequently filed a motion to suppress the evidence collected during the initial traffic stop.
Facts of the Case
According to the opinion, David Alfaro, an officer with the City of Corpus Christi Police Department, was the sole witness for the prosecution. Officer Alfaro testified that he observed a U-Haul truck parked at a fast food restaurant in Corpus Christi around 1:19 A.M. Officer Alfaro stated that he had received a notice to be on the lookout for a U-Haul truck that had been involved in multiple local burglaries. As a result, he followed the U-Haul in his marked patrol car onto the I-37 highway before observing the U-Haul truck’s fires cross the line into the adjacent lane briefly. Officer Alfaro then initiated a traffic stop based on his suspicion that the defendant failed to maintain the vehicle in a single lane.
At trial, the court admitted Officer Alfaro’s dash-cam video footage. The footage depicts the defendant’s U-Haul traveling in the center lane of a three-lane highway. The U-Haul truck is the only vehicle visible in the footage for the duration of the video. The passenger side rear tire of the U-Haul truck can be seen briefly straddling the lane divider after rounding a curve. The U-Haul truck then moves towards the opposite lane divide, remaining in its lane. Officer Alfaro then activated his patrol lights and initiated the traffic stop. The trial court found that Officer Alfaro lacked reasonable suspicion to stop the defendant and granted the defendant’s motion to suppress.
The Decision
On appeal, the State argued that the trial court erred by concluding that Officer Alfaro lacked reasonable suspicion to stop the defendant for committing a traffic offense. Specifically, the State maintains that failure to maintain a single lane, whether or not it can be done safely, is a traffic violation, which by itself provided sufficient reasonable suspicion for Officer Alfaro to make the stop. The appeals court opinion disagreed. After viewing the dash-cam video footage and listening to Officer Alfaro’s testimony, the trial court found that the defendant’s actions were not unsafe, which the State did not challenge on appeal. As a result, in accordance with the appeals court precedent, the appellate decision concluded that Officer Alfaro did not have reasonable suspicion to stop the defendant. As that was the only articulated basis for the detention, the appellate court held that the trial court did not err in granting the defendant’s motion to suppress, overruling the State’s sole claim.
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