Elvis Elvis Ramirez-Tamayo v. State, 07-15-00419-CR

Deputy with ~8 years as a peace officer and highway/interdiction experience stopped appellant for speeding on I‑40 in Texas; appellant was driving a Florida rental 2014 car.
After issuing a warning, the deputy approached and observed the passenger (appellant) reach across the front seat and open the passenger door rather than roll down the (electric) window. The window did not roll down.
Deputy detected strong cologne and cigarette smoke; testified that traffickers sometimes use cover odors and that door cavities are commonly used to hide drugs on I‑40.
Appellant displayed pronounced nervousness (constant shifting, crossing arms) that did not abate after being told he would receive only a warning.
Trial court denied suppression of evidence seized after continued detention; majority of appellate court concluded the continued detention lacked reasonable suspicion, but Justice Campbell dissented, arguing the deputy had particularized, objective facts supporting reasonable suspicion and that implicit factual findings should be viewed in the light most favorable to the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether deputy had reasonable suspicion to prolong detention beyond traffic stop	Deputy (State) argued: reaching across seat to open passenger door, strong cologne and cigarette odor, and extreme nervousness created particularized, objective suspicion of drug trafficking	Appellant argued: facts were innocent or equivocal (window malfunction, common nervousness), insufficient to support reasonable suspicion under Rodriguez	Majority: continued detention was unlawful (no reasonable suspicion). Dissent: facts were particularized and reasonable, would affirm denial of suppression
Proper standard of appellate review of trial court’s factual findings	State argued appellate court must view evidence in light most favorable to trial court, giving deference to implicit findings	Appellant argued evidence did not objectively support trial court’s decision; no deference changes result	Dissent emphasized deference to trial court and implicit findings supported reasonable suspicion; majority applied de novo evaluation and found suspicion lacking

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (prolonging a traffic stop beyond mission requires reasonable suspicion of additional criminal activity)
United States v. Sokolow, 490 U.S. 1 (1989) (framework for assessing whether officer had reasonable suspicion based on totality of circumstances)
Hamal v. State, 390 S.W.3d 302 (Tex. Crim. App. 2012) (descriptions of reasonable suspicion standard)
Valtierra v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (standard for reviewing record when trial court issues no formal findings)
Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (appellate review deference to trial court’s implicit factual findings)