Brayan Josue Oliva-Arita v. State, 01-15-00140-CR

Appellant Brayán Josué Oliva-Arita was stopped after an officer ran a license-plate check that returned an "unconfirmed" insurance status for his vehicle; the officer then conducted a DWI investigation that led to arrest.
Officer Jose Lobo testified he does not know who maintains the insurance database, how often it is updated, or its error rate; he estimated from experience it is accurate about 75% of the time.
The officer acknowledged the database sometimes produces false positives and could return one of three responses: confirmed, unconfirmed with details (e.g., expired >45 days, carrier), or unconfirmed with no details.
Appellant moved to suppress evidence obtained after the stop, arguing (1) the State failed to prove the insurance database is a reliable source and (2) an unconfirmed return without corroborating details does not supply reasonable suspicion or probable cause.
The trial court denied the motion to suppress; Appellant pleaded nolo contendere, received a plea-bargain sentence, and appealed the denial of the suppression motion (right to appeal certified).

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Whether the State proved the insurance database is a reliable informant	Oliva-Arita: State presented no foundational evidence about database accuracy, administration, timeliness, or operating history; database is effectively an anonymous informant and cannot alone justify a stop.	State: (implicit) officer reliance on routine plate-check database results provides a sufficient basis for the stop.	Trial court denied suppression (appeal argues this was abuse of discretion).
2. Whether an "unconfirmed" response alone creates reasonable suspicion to stop	Oliva-Arita: A bare "unconfirmed" response lacks specific, articulable facts and cannot supply reasonable suspicion or probable cause.	State: (implicit) a computerized insurance check can furnish reasonable suspicion when it indicates lack of required financial responsibility.	Trial court denied suppression (appeal contends controlling precedent requires more detail than a bare "unconfirmed").

Contraras v. State, 309 S.W.3d 168 (Tex. App.—Amarillo 2010) (discussing limits on relying on unverified database results to justify stops)
Crawford v. State, 355 S.W.3d 193 (Tex. App.—Houston [1st Dist.] 2011) (holding an unconfirmed result with specific ancillary details can supply reasonable suspicion)
State v. Sheppard, 271 S.W.3d 281 (Tex. Crim. App. 2008) (standard for reasonable-suspicion investigative detention)
Davis v. State, 947 S.W.2d 240 (Tex. Crim. App. 1997) (articulable-facts requirement for investigative stops)
Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (temporary detention standard under reasonable suspicion)
Gonzalez-Gilando v. State, 306 S.W.3d 893 (Tex. App.—Amarillo 2010) (insufficient to rely on a database response that is not detailed or reliable)
State v. Daniel, 446 S.W.3d 809 (Tex. App.—San Antonio 2014) (holding a lone "unconfirmed" database response did not support reasonable suspicion)