Brian Eugene Woodard v. State, 06-14-00221-CR

Brian Eugene Woodard was indicted for possession of cocaine (≥400 grams) and tried non-jury in Hunt County, Texas; convicted and sentenced to 40 years.
DPS Officer Zane Rhone stopped Woodard on I‑30; stated reasons included following-too-close and an allegedly obscured license‑plate state name.
Rhone testified he smelled air freshener, the car was clean, and that he later saw Ohio plates and learned the dealer-installed plate frame likely obscured the plate. Woodard’s grandfather corroborated the dealer‑installed frame.
Rhone acknowledged his written report did not mention following‑too‑close and also admitted he began but had not completed the warning before further questioning/search.
Appellant’s brief argues the stop was pretextual and unlawful (Texas should apply Ohio law and full faith and credit), and that detention exceeded time necessary for the traffic stop, so the subsequent search/seizure (and contraband) should have been suppressed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Woodard)	Held
1. Lawfulness of the stop (probable cause/ pretext)	Officer Rhone had grounds to stop for following‑too‑close and obstructed/illegible plate.	Stop was pretextual and unsupported: Rhone’s report omitted following‑too‑close, observations conflicted, and Ohio law permitted the plate/frame; Texas must give full faith and credit to Ohio law.	Trial court admitted Rhone’s testimony and evidence; Woodard appeals admission as reversible error.
2. Duration and scope of detention (Rodriguez/Terry limits)	Further questioning/search was within permissible on‑scene inquiries and incident to traffic enforcement.	Rhone prolonged the stop beyond the time needed to issue a warning; authority to detain ended when traffic tasks were (or reasonably should have been) completed, so later search/seizure violated the Fourth Amendment.	Trial court admitted the search evidence; Woodard contends this was unlawful and seeks suppression/reversal.

Terry v. Ohio, 392 U.S. 1 (1968) (framework for investigatory stops and limited intrusions)
Delaware v. Prouse, 440 U.S. 648 (1979) (limits on stops and checks of drivers for arbitrary enforcement)
United States v. Sharp, 470 U.S. 675 (1985) (authority for seizure ends when tasks tied to traffic infraction are completed)
Florida v. Royer, 460 U.S. 491 (1983) (scope of detention must be tailored to justification)
Illinois v. Caballes, 543 U.S. 405 (2005) (use of a dog during a lawful traffic stop may be permissible but stop’s purpose limits duration)
Rodriguez v. United States, 575 U.S. 348 (2015) (extending a traffic stop beyond completion of mission without reasonable suspicion is unlawful)
Walters v. State, 247 S.W.3d 204 (Tex. Crim. App. 2007) (standard of review for trial court evidentiary rulings)
Ford v. State, 158 S.W.3d 488 (Tex. Crim. App.) (stopping for following‑too‑close must be supported by more than conclusory statements)
United States v. Smith, 799 F.3d 704 (11th Cir.) (assessment of whether a stop was unreasonably pretextual)