Alexander Lee Grubbs v. State
05-15-01429-CR
| Tex. App. | Oct 6, 2016Background
- Early morning traffic stop in Grayson County after two officers observed a vehicle allegedly run a stop sign; officers testified headlights never paused, indicating no stop.
- Officers stopped the vehicle, determined Alexander Lee Grubbs was intoxicated, and arrested him for DWI.
- Grubbs filed a pretrial motion to suppress evidence, which the trial court declined to rule on, stating the factual issues would be submitted to the jury.
- At trial Grubbs denied failing to stop and argued on appeal the stop lacked reasonable suspicion and that the trial court should have resolved statutory interpretive issues concerning stop-sign provisions before trial.
- The appellate court considered preservation of error and, alternatively, whether the stop was supported by reasonable suspicion based on the officers’ testimony.
Issues
| Issue | Plaintiff's Argument (Grubbs) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the trial court erred by not resolving statutory ambiguity before trial and admitting evidence from an unconstitutional stop | Trial court should have interpreted overlapping stop-sign statutes in Grubbs’s favor (in pari materia) and suppressed evidence because ambiguity creates doubt about whether a violation occurred | Grayson County officers observed a traffic violation (failure to stop); stop was supported by reasonable suspicion and Grubbs did not raise this statutory-interpretation argument at trial | Error not preserved; alternatively, officers had reasonable suspicion to stop based on testimony they saw the vehicle fail to stop, so suppression denial was proper |
Key Cases Cited
- Black v. State, 362 S.W.3d 626 (Tex. Crim. App. 2012) (motion to suppress is an objection to admissibility)
- Pena v. State, 285 S.W.3d 459 (Tex. Crim. App. 2009) (appellate complaints must comport with trial objections)
- Lovill v. State, 319 S.W.3d 687 (Tex. Crim. App. 2009) (new legal bases on appeal not preserved)
- Posey v. State, 966 S.W.2d 57 (Tex. Crim. App. 1998) (trial court must have opportunity to rule and record developed on issues)
- Turrubiate v. State, 399 S.W.3d 147 (Tex. Crim. App. 2013) (bifurcated standard for reviewing suppression rulings)
- Kerwick v. State, 393 S.W.3d 270 (Tex. Crim. App. 2013) (reasonable-suspicion question reviewed de novo)
- Lloyd v. State, 453 S.W.3d 544 (Tex. App.—Dallas 2014) (application of suppression-review standards)
- Kelly v. State, 204 S.W.3d 808 (Tex. Crim. App. 2006) (implied findings support trial rulings when no findings issued)
- Valtierra v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (deference to trial court credibility and demeanor findings)