Alberto Garcia v. State, 08-13-00178-CR

Appellant Garcia was stopped at night after allegedly passing in a no-passing zone on a curve with double yellow lines and following too closely.
Trooper Conn testified Garcia was passing in a no-passing zone and following too closely, which are traffic-law violations.
After the stop, Trooper Conn observed signs of intoxication and Garcia was arrested for DWI.
The trial court denied the motion to suppress and found Garcia’s stop occurred because of the observed traffic violation.
Appellant argued Ford v. State requires specific, articulable facts beyond a bare opinion that Garcia was following too closely.
The court affirmed the trial court, concluding the no-passing, on-curve violation supports reasonable suspicion for the stop under Castro and related precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether stop based on passing in a no-passing zone is objectively reasonable	Garcia argues Ford requires detailed facts; no specific facts beyond following too closely.	State contends no-passing violation provides objective basis for stop.	Yes; stop sustained based on no-passing-zone violation as objective

Ford v. State, 158 S.W.3d 488 (Tex.Crim.App. 2005) (requires specific, articulable facts to support reasonable suspicion)
Castro v. State, 227 S.W.3d 737 (Tex.Crim.App. 2007) (distinguishes when objective vs. subjective determinations require detailed observations)
Crain v. State, 315 S.W.3d 43 (Tex.Crim.App. 2010) (standard of review for suppression rulings; deference to trial court findings)
Valtierra v. State, 310 S.W.3d 442 (Tex.Crim.App. 2010) (outline of mixed questions and de novo review for legal conclusions)
Amador v. State, 221 S.W.3d 666 (Tex.Crim.App. 2007) (principles for reviewing credibility-based determinations)
Guzman v. State, 955 S.W.2d 85 (Tex.Crim.App. 1997) (reiteration of reasonable-suspicion standards)
Romero v. State, 800 S.W.2d 539 (Tex.Crim.App. 1990) (earlier articulation on reasonable suspicion standards)