Clifton Crews Hoyt v. State, 03-15-00228-CR

On Feb. 11, 2013 Officer Antonio Aguilar (San Angelo PD) received a broadcast of a reckless motorcycle driver with a license plate; the plate ran to Clifton Crews Hoyt.
Aguilar followed Hoyt, observed the motorcycle accelerate away from a traffic signal in a manner consistent with San Angelo’s exhibition-of-acceleration ordinance, and then initiated a stop.
Aguilar knew from prior contacts that Hoyt’s driver’s license had been suspended and that Hoyt lacked a motorcycle endorsement; Hoyt acknowledged the license was invalid on video.
After stopping, Aguilar observed Hoyt acting unusually (inappropriate dress for weather, agitation, fidgeting), performed SFSTs (no HGN clues; multiple clues on walk-and-turn and one-leg-stand), arrested him for DWI, and found <2 oz. marijuana on his person; Hoyt refused breath testing.
Trial court denied Hoyt’s motion to suppress; Hoyt was convicted of felony DWI (based on prior DWI convictions). The State appeals/briefed issues defending the denial and sufficiency of evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hoyt)	Held
1. Whether the stop was lawful (motion to suppress)	Aguilar had objective basis: broadcast of reckless motorcyclist, matching plate, observed exhibition of acceleration, knew Hoyt’s license was suspended and no endorsement, and observed traffic violations and evasive conduct — reasonable suspicion/probable cause for stop and to investigate intoxication	Hoyt argued the stop was pretextual/intended to investigate intoxication and that the acceleration was not supported by testimony/video; also disputed weather/behavior significance	Trial court denied suppression; State argues denial correct because objective facts (broadcast, plate match, observed acceleration, license status) gave lawful basis for stop and subsequent intoxication investigation
2. Sufficiency of evidence for DWI conviction (intoxication element)	Totality of circumstances (driving, behavior, SFST performance, officer training/DRE, discovery of marijuana, refusal to give breath) supports finding Hoyt lacked normal use of faculties beyond a reasonable doubt	Hoyt contended evidence was insufficient — officer relied on non-specific indicators (shorts in mild weather, agitation); pointed to absence of chemical test/blood warrant and other omissions	State argues (and trial court found) evidence was sufficient: officer testimony, SFST clues, behavior changes, contraband, and refusal supported intoxication; conviction sustained

Brinegar v. United States, 338 U.S. 160 (probable cause analyzed under totality of circumstances)
Davis v. State, 947 S.W.2d 240 (Tex. Crim. App.) (traffic stop requires reasonable suspicion of traffic violation)
Garcia v. State, 43 S.W.3d 527 (Tex. Crim. App.) (reasonable-suspicion inquiry is objective and considers totality of circumstances)
Jackson v. Virginia, 443 U.S. 307 (legal-sufficiency standard — review in light most favorable to verdict)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App.) (defining legal-sufficiency review in Texas)
Byrd v. State, 336 S.W.3d 242 (Tex. Crim. App.) (State must prove every element beyond reasonable doubt)
Annis v. State, 578 S.W.2d 406 (Tex. Crim. App.) (officer testimony that a person is intoxicated can be sufficient evidence)