Christopher Jaroszewicz v. Texas Department of Public Safety, 03-15-00340-CV

Appellant Jaroszewicz challenged the DPS suspension of his driver’s license after an Austin officer observed him speeding in a 30 mph zone.
Officer Martin testified Jaroszewicz passed West 6th Street at a high rate of speed and measured 45 mph with Doppler radar.
Jaroszewicz was arrested for driving while intoxicated and refused to provide a breath or blood specimen.
SOAH sustained the license suspension after an evidentiary hearing; the trial court affirmed the ALJ’s ruling.
Jaroszewicz objected at the ALR hearing to Officer Martin’s speeding statements and radar readout; the objection was general and not granular.
The appellate argument centered on whether the radar/readout and the officer’s lay speed opinion were admissible and whether they established reasonable suspicion to stop.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the objection preservation proper?	Jaroszewicz preserved error with a general objection.	Objection was too general to preserve any basis for review.	Objection was not preserved; should be overruled.
Did the radar and visual speed evidence establish reasonable suspicion to stop?	Radar/readout and visual estimate provided reasonable suspicion when combined with observations.	Radar/readout not required; officer’s lay opinion sufficed to show speeding and reasonable suspicion.	Yes; stop supported by reasonable suspicion; radar corroboration not legally required.

Dillard v. State, 550 S.W.2d 45 (Tex. Crim. App. 1977) (human observation can establish reasonable suspicion for speeding)
Icke v. State, 36 S.W.3d 913 (Tex. App.—Houston [1st Dist.] 2001) (officer's speed estimation admissible as lay opinion)
Parroccini v. State, 234 S.W. 671 (Tex. Crim. App. 1921) (lay opinions on speed recognized as admissible)
Amores v. State, 816 S.W.2d 407 (Tex. Crim. App. 1991) (totality of circumstances approach to admissibility and reasonableness)