Coleman v. State, 2011 Tex. App. LEXIS 10152

Houston police undercover surveillance followed Coleman after tip about a truck delivering cash or narcotics to a local house in Harris County.
Coleman arrived in a truck matching the tip description and failed to signal a turn, drawing police attention.
Officers directed by radio to Coleman's destination, a residence in Missouri City, within Harris County, shortly after the traffic stop occurred.
Coleman was arrested at the house; a pat-down occurred after he exited his vehicle, during which cocaine was discovered in his left jacket pocket.
A search warrant for the house yielded additional cocaine; Coleman moved to suppress all cocaine evidence obtained.
Trial court denied suppression; Coleman pleaded guilty to possession with intent to deliver and received a 45-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether arrest outside jurisdiction complied with 14.03(g)(2)	Coleman argues Raven lacked authority for an out-of-jurisdiction arrest.	State contends officers were authorized under 14.03(g)(2) as present or viewing the offense.	Arrest authorized under 14.03(g)(2).
Whether pat-down/search was constitutional	Coleman contends lack of justification for frisk.	State maintains reasonable safety frisk was permissible.	Issue waived; court overruled but notes waiver.

Willis v. State, 669 S.W.2d 728 (Tex.Crim.App. 1984) (presence/view suffices for arrest when part of surveillance team)
Astran v. State, 799 S.W.2d 761 (Tex.Crim.App. 1990) (viewing officer may be part of arrest team without physically seizing)
Ex parte Keller, 173 S.W.3d 492 (Tex.Crim.App. 2005) (statutory consistency in interpretations of 'presence' or 'view')
Miller v. State, 33 S.W.3d 257 (Tex.Crim.App. 2000) (acquiescence rule: legislature presumed aware of case law affecting statute)
Marin v. State, 891 S.W.2d 267 (Tex.Crim.App. 1994) (presumption of continued application of judicial construction)