Alejandro Castro v. State
373 S.W.3d 159
| Tex. App. | 2012Background
- Castro challenged the denial of his motion to suppress after pleading nolo contendere to two counts of second‑degree robbery; the trial court denied the motion.
- Victims Martinez and Zamarippa were assaulted in Travis Park, football-like confrontation with four men demanding belongings; Martinez was injured and robbed of his wallet; Zamarippa’s skateboard was taken.
- Officer Barrow, on bike patrol, received secondhand reports of a fight and later observed suspects matching descriptions near the park; he initially detained two men (Hinojosa and Vasquez).
- Castro was identified at a restaurant when Barrow encountered him; Castro was handcuffed and temporarily detained, then taken along with others for an on-site lineup to identify the suspects.
- The defense argued the detention was an unlawful warrantless arrest and should have led to suppression; the State argued it was an investigatory detention supported by reasonable suspicion; the trial court denied suppression and Castro pled guilty/condensed to judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Detention vs. arrest in Castro’s stop | Castro: detention was an unlawful arrest | State: detention was investigatory, not an arrest | Detention was investigative, not an arrest |
Key Cases Cited
- Amores v. State, 816 S.W.2d 407 (Tex. Crim. App. 1991) (detention may be investigatory under reasonable suspicion)
- State v. Sheppard, 271 S.W.3d 281 (Tex. Crim. App. 2008) (framework for distinguishing detention from arrest (totality of circumstances))
- Curtis v. State, 238 S.W.3d 376 (Tex. Crim. App. 2007) (totality of circumstances in detention adequacy)
- Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (reasonable suspicion standard for investigative stops)
- Balentine v. State, 71 S.W.3d 763 (Tex. Crim. App. 2002) (handcuffing for safety during investigative detention is permissible)
- Mays v. State, 726 S.W.2d 937 (Tex. Crim. App. 1986) (investigative detention with temporary restraints for safety)
- Rhodes v. State, 945 S.W.2d 115 (Tex. Crim. App. 1997) (detention reasonableness depends on circumstances, not rigid test)
- Amador v. State, 221 S.W.3d 666 (Tex. Crim. App. 2007) (defer to trial court on historical facts and credibility; de novo on legal conclusions)
- State v. Elias, 339 S.W.3d 667 (Tex. Crim. App. 2011) (reasonable suspicion standard applied to detention)