Efren Saenz v. State, 564 S.W.3d 469

At ~2:00 a.m., Officer Robles observed Appellant’s vehicle slow to nearly a stop at a green light and noticed the vehicle’s right rear stoplamp did not illuminate.
Robles stopped the vehicle and observed signs of intoxication (slurred speech, bloodshot eyes, odor of alcohol); Appellant admitted drinking and had no ID/insurance.
A DWI task‑force officer administered field sobriety tests, concluded Appellant was intoxicated, and arrested him; multiple open warrants for Appellant were confirmed after arrest.
Appellant moved to suppress evidence, arguing the traffic stop was unlawful because federal regulations only require a vehicle be equipped with three stoplamps and, since the left and high‑mounted lamps worked, the vehicle complied with the code.
The State argued Texas adopted the federal FMVSS No. 108, which for narrower vehicles (under 2032 mm) requires a functioning third (high‑mounted) stoplamp and that operating a vehicle with a non‑functioning required lamp violates Tex. Transp. Code §547.004, giving probable cause for the stop.
The trial court denied suppression; the court of appeals affirmed, holding the vehicle was subject to the three‑lamp federal standard, the right lamp failed to activate, and the stop was justified.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was lawful where one rear stoplamp failed to illuminate	Saenz: federal regs only require a vehicle be equipped with three lamps; two visible lamps (left + high‑mounted) meant the vehicle complied, so stop lacked probable cause	State: Texas adopted FMVSS No. 108; vehicle was under width/weight thresholds so required three lamps that must activate when braking; non‑activated lamp is a vehicle equipment violation giving reasonable suspicion/probable cause	Stop lawful: vehicle required a working third lamp, right stoplamp failed to activate, so officer properly stopped the vehicle; suppression denied

Delafuente v. State, 414 S.W.3d 173 (Tex. Crim. App. 2013) (reasonable‑suspicion standard for investigative stops)
Crain v. State, 315 S.W.3d 43 (Tex. Crim. App. 2010) (abuse‑of‑discretion review of suppression rulings)
Ramos v. State, 245 S.W.3d 410 (Tex. Crim. App. 2008) (appellate review and upholding trial court if supported under any applicable theory)
Alford v. State, 358 S.W.3d 647 (Tex. Crim. App. 2012) (deference to trial court on historical facts and credibility; standard for mixed questions)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (reviewing suppression evidence in light most favorable to the trial court)
Schwintz v. State, 413 S.W.3d 192 (Tex. App.—Beaumont 2013) (vehicle‑equipment stop for nonfunctioning stoplamp upheld)