Francheska v. Jaganathan v. State
438 S.W.3d 823
| Tex. App. | 2014Background
- Appellant Francheska V. Jaganathan appeals the trial court’s denial of a motion to suppress evidence seized during a traffic stop.
- Officer detained Jaganathan for driving in the left lane without passing, based on a left-lane-for-passing-only sign.
- The stop occurred after the officer smelled marijuana and conducted a search that yielded marijuana in the trunk.
- The stop was challenged as an unlawful detention lacking reasonable suspicion under the Fourth Amendment.
- The appellate court held the detention was not supported by reasonable suspicion and reversed and remanded for a new trial.
- The court assessed whether the suppression ruling was harmful under TEX. R. APP. P. 44.2(A) and concluded the error was harmful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop supported by reasonable suspicion? | Jaganathan asserts lack of reasonable suspicion. | State contends observed passing behavior justified the stop. | No reasonable suspicion; stop invalid. |
Key Cases Cited
- Abney v. State, 394 S.W.3d 542 (Tex. Crim. App. 2013) (standard for reasonable suspicion; totality of the circumstances)
- Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (burden-shifting on warrants and reasonableness of seizure)
- Wardlow, 528 U.S. 119 (2000) (reasonable-suspicion standard; totality of circumstances)
- Duran v. State, 396 S.W.3d 570 (Tex. Crim. App. 2013) (review of video evidence and timing in traffic-stop context)
- Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (evidence-based assessment of traffic-violation grounds)