Background

• Perrin was charged with DWI in Collin County and found guilty at trial; the stop occurred as she was pulling out of a parking spot on Twin Creeks Drive in Allen at about 12:30 a.m.
• Officer Brown stopped Perrin allegedly to check why her car door was open and she was walking among other vehicles; Perrin argues the door was not visibly open in the video.
• Video evidence reportedly shows the car door closed, contradicting officer's account; Perrin contends the stop was not based on illegal activity.
• Evidence post-stop included field sobriety tests, DRE testimony, a blood draw, and lab analysis showing prescription medications; Perrin argues such evidence should be suppressed if the stop was unlawful.
• The trial court denied the motion to suppress; Perrin appeals seeking reversal and remand for suppression of post-stop evidence.
• The appellate argument centers on whether the initial detention was supported by reasonable suspicion or justified under community caretaking.

Issues

Key Cases Cited

• Berkemer v. McCarty, 468 U.S. 420 (U.S. Supreme Court 1984) (physically regulated stops require reasonable suspicion)
• Ford v. State, 158 S.W.3d 488 (Tex.Crim.App. 2005) (reasonable suspicion governs automobile stops)
• Garcia v. State, 43 S.W.3d 527 (Tex.Crim.App. 2001) (informational stops require articulable facts)
• Crain v. State, 315 S.W.3d 43 (Tex. Crim. App. 2010) (nighttime detentions and ambiguous activity require suspicion)
• St. George v. State, 237 S.W.3d 720 (Tex.Crim.App. 2007) (articulable suspicion standards for detentions)
• Corbin v. State, 85 S.W.3d 272 (Tex.Crim.App. 2002) (community caretaking exception requires purpose and reasonableness)
• Montanez v. State, 195 S.W.3d 101 (Tex.Crim.App. 2006) (suppression preserved when motion denied and evidence later offered)