Crider, Robert Jackson, II
PD-1248-14
| Tex. App. | Feb 25, 2015Background
- Appellant Robert Jackson Crider II appealed a traffic-stop suppression issue arising from a Y-intersection where Vinson Road ends at a stop sign and splits into FM 544 and County Line Road.
- At the intersection the stopped driver had to choose left or right; a ditch lay opposite the stop sign and the rightward path was at a steeper angle.
- The court of appeals described all three roads as "equally travelled" and found no direct flow of traffic because the stop sign forced a choice of path.
- The legal question centered on whether the movement from Vinson Road constituted a "turn" under Tex. Transp. Code §545.104(a) (affecting the duty to signal), or some other maneuver requiring different treatment.
- The Texas Court of Criminal Appeals declined discretionary review; Justice Newell concurred in that refusal and explained why the lower courts correctly applied existing law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether movement at the Y-intersection required a turn signal under §545.104(a) | Crider argued the facts did not show a "turn" requiring a signal (implied challenge to stop-and-choose configuration) | State maintained the movement qualified as a turn subject to the statutory definition and thus signaling rules applied | Court of Criminal Appeals declined review; concurrence agreed the court of appeals properly applied Mahaffey’s definition of "turn" and found no reason to revisit precedent |
| Whether the intersection had a "direct flow" of traffic negating the need to treat the maneuver as a turn | Crider implied the geometry might not be a turn if flow continued | State argued stop sign and split forced a directional choice, so it was a turn | Court of appeals: stop sign terminated direct flow; concurrence agreed and declined to disturb that factual application |
| Whether Mahaffey’s definition of "turn" is ambiguous or should be revisited | Crider (and dissent) suggested more nuanced analysis might be needed for Y‑intersections | State relied on Mahaffey’s plain-meaning definition: change of direction from direct course | Concurrence: Mahaffey’s common-meaning definition is unambiguous; not appropriate case to revisit it |
| Whether more legislative or doctrinal guidance is needed for complex intersections | Crider/dissent urged further guidance on signals at Y intersections | State relied on existing statutory and case law to resolve the suppression issue | Concurrence: Acknowledged the policy questions but deferred to legislature; existing law provided sufficient guidance for this case |
Key Cases Cited
- Mahaffey v. State, 316 S.W.3d 633 (Tex. Crim. App. 2010) (defines "turn" as changing directions from the direct course or flow of traffic)
- Robinson v. State, 377 S.W.3d 712 (Tex. Crim. App. 2012) (addressed signaling at intersections and left lower-court determination that a signal was required)