Cristan Drayce Williams v. State, 10-14-00307-CR

Appellant Cristan Drayce Williams was stopped in a nearly empty parking garage at about 3:00 a.m., one hour after nearby bars had closed; his vehicle engine was running.
Sgt. Jason Summers, on bicycle patrol, observed Williams’ parked car and checked the upper level before returning and seeing Williams drive at least three laps around the second level.
Summers suspected intoxication (difficulty locating the exit/ramp) and detained Williams; Williams was arrested for DWI and possession of marijuana.
Williams moved to suppress, arguing the detention lacked reasonable suspicion; the trial court denied the motion.
Williams pled guilty to possession of marijuana (under two ounces), with deferred adjudication and 18 months community supervision; he appealed the denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer had reasonable suspicion to detain Williams for an investigatory stop	Williams: driving laps was not unlawful or sufficiently distinguishable from innocent behavior, so no reasonable suspicion	State: repeated laps in a nearly empty garage at 3 a.m. soon after bars closed was unusual and consistent with possible intoxicated driving	Court: Officer had reasonable suspicion under the totality of circumstances; suppression denied

State v. Robinson, 334 S.W.3d 776 (Tex. Crim. App. 2011) (standard for reviewing suppression rulings)
State v. Kelly, 204 S.W.3d 808 (Tex. Crim. App. 2006) (evidentiary review principles for suppression hearings)
Wiede v. State, 214 S.W.3d 17 (Tex. Crim. App. 2007) (trial judge as factfinder and credibility determinations)
Amador v. State, 221 S.W.3d 666 (Tex. Crim. App. 2007) (deference to trial court on historical facts and credibility-based applications)
Hereford v. State, 339 S.W.3d 111 (Tex. Crim. App. 2011) (de novo review for application-of-law-to-fact questions not based on credibility)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (totality-of-circumstances test for investigatory stops)
Florida v. Royer, 460 U.S. 491 (U.S. 1983) (limits on detention length for investigatory stops)
Castro v. State, 227 S.W.3d 737 (Tex. Crim. App. 2007) (definition of reasonable suspicion)
Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (elements of unusual activity linking person to crime)
Wade v. State, 422 S.W.3d 661 (Tex. Crim. App. 2013) (suspect’s behavior must be distinguishable from innocent conduct)
Crockett v. State, 803 S.W.2d 308 (Tex. Crim. App. 1991) (behavior must set suspect apart from innocent people)