713 S.W.3d 893
Tex. Crim. App.2025Background
- Officer received a report of erratic driving and found the suspect's vehicle at an apartment complex.
- Witnesses confirmed the vehicle's description and provided details about the suspect's appearance and behavior.
- Officers identified the suspect (Armstrong), who appeared intoxicated and matched witness descriptions, and arrested him for DWI without a warrant.
- Armstrong moved to suppress evidence, arguing that his warrantless arrest was invalid because there were no exigent circumstances as allegedly required by Texas Code of Criminal Procedure art. 14.03(a)(1).
- The trial court denied the motion; the court of appeals reversed, holding that exigent circumstances were required for such an arrest.
- The Texas Court of Criminal Appeals granted review to decide if exigency is actually required under Article 14.03(a)(1).
Issues
| Issue | Armstrong's Argument | State's Argument | Held |
|---|---|---|---|
| Does Article 14.03(a)(1) require exigent circumstances for a warrantless arrest in a 'suspicious place'? | Exigency is required for a valid arrest under 14.03(a)(1), so arrest was unlawful without it. | Exigency is not required by the statute for a warrantless arrest in a 'suspicious place.' | No exigency required; exigency may be a factor, but not an element. |
Key Cases Cited
- Dyar v. State, 125 S.W.3d 460 (Tex. Crim. App. 2003) (totality of the circumstances test governs whether a place is 'suspicious' under art. 14.03(a)(1))
- Gallups v. State, 151 S.W.3d 196 (Tex. Crim. App. 2004) (arrest in home can satisfy 'suspicious place' with probable cause and exigent circumstances)
- Swain v. State, 181 S.W.3d 359 (Tex. Crim. App. 2005) (exigency discussed as a possible factor, not a statutory requirement, for warrantless arrest under Article 14.03(a)(1))