Crider, Robert Jackson, II, PD-1248-14

Background

Robert J. Crider II was stopped for allegedly failing to signal at a “Y” intersection where Vinson Road meets FM 544 and County Line Road; Crider was driving northbound and encountered a stop sign before continuing onto FM 544.
The traffic stop led to a motion to suppress evidence; suppression was denied, conviction followed, and Crider sought discretionary review.
The Court of Criminal Appeals refused review but issued a published dissent (Keller, P.J., joined by Hervey) and a concurrence (Newell, J., joined by Johnson) discussing whether the statute is clear as applied to Y‑intersections.
Central factual dispute: whether the movement from Vinson onto FM 544 constituted a “turn” (requiring a signal) or continuation of the roadway. Crider argues his movement was a slight curve and not a turn.
Legal focus: interpretation and as‑applied constitutionality of Tex. Transp. Code § 545.104(a) (turn signal requirement) at Y‑intersections and whether the statute gives fair notice or invites arbitrary enforcement.

Issues

Issue	Plaintiff's Argument (Crider)	Defendant's Argument (State)	Held
Whether Crider’s motion to suppress should have been granted (stop unlawful)	Stop unlawful because statute is vague as applied; Crider’s movement was not a "turn" requiring a signal	Stop lawful because court of appeals correctly found a signal required where direct flow terminated at the stop/signaled Y	Court of Criminal Appeals refused review; dissent would grant review to clarify law; concurrence declined to revisit Mahaffey definition of “turn.”
When is a turn signal required at a Y‑intersection?	Y‑intersections create ambiguity; statute cannot be applied uniformly—no clear notice	Court of appeals: where direct flow terminates (choice to go left/right) a signal is required	No definitive rule adopted by CCA; concurring opinion relied on Mahaffey standard (signal required when deviating from direct course).
Did Crider’s movement require a signal under §545.104(a)?	Movement was a slight curve, not a deviation from direct course; as‑applied statute is unconstitutionally vague	Movement required a signal because stop sign forced a choice and ended direct flow	Lower courts held a signal was required; CCA denied review, leaving that outcome intact.
Is §545.104(a) unconstitutional as applied to Crider?	Yes — fails fair‑notice/void‑for‑vagueness and risks arbitrary enforcement	No — statute and Mahaffey definition provide adequate guidance	CCA did not hold statute unconstitutional; concurrence acknowledged concerns but declined to strike or clarify beyond Mahaffey.

Key Cases Cited

Mahaffey v. State, 316 S.W.3d 633 (Tex. Crim. App. 2010) (defines “turn” as deviating from the direct course/flow of the roadway)
Robinson v. State, 377 S.W.3d 712 (Tex. Crim. App. 2012) (addresses legal significance of roadway character in signal cases)
Busic v. United States, 446 U.S. 398 (U.S. 1980) (lenity and resolving ambiguity in favor of defendants)
United States v. Bass, 404 U.S. 336 (U.S. 1971) (ambiguities in criminal statutes construed narrowly)
Papachristou v. City of Jacksonville, 405 U.S. 156 (U.S. 1972) (void‑for‑vagueness principles concerning notice and arbitrary enforcement)
Thomas v. State, 919 S.W.2d 427 (Tex. Crim. App. 1996) (doubt about whether an offense was committed should favor the accused)