Geraline Gregory Lincoln v. State, 14-14-00959-CR

Appellant Geraline Gregory Lincoln was stopped by deputies after driving conduct observed on Saratoga, Whitter Forest, and Wildforest Drive; deputies testified to multiple traffic violations including failure to maintain a single lane, rolling a stop sign, and multiple failures to signal turns.
Dash-cam video admitted did not clearly show four of the alleged violations but did show the vehicle turning into a driveway without a visible turn signal; deputies explained camera positioning for the omissions.
Appellant testified he drove lawfully: stopped at the stop sign and used turn signals; there was no other traffic.
Trial court found officers credible, concluded there were five discrete reasons supporting the stop, found the video did not contradict officer testimony, and held the stop was supported by reasonable suspicion.
After the stop, outstanding warrants led to appellant’s arrest; a search incident to arrest discovered a firearm and controlled substances. Appellant pleaded guilty after his motion to suppress was denied and was sentenced to concurrent eight-year terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop lacked reasonable suspicion because video did not show violations	Lincoln: video and his testimony show he obeyed stop sign and used signals; no reasonable basis for stop	State: officers reasonably suspected traffic violations based on observed driving and officer testimony; video doesn’t disprove violations	Court: Affirmed — trial court reasonably credited officers and video did not indisputably contradict their testimony; stop was supported by reasonable suspicion

Berkemer v. McCarty, 468 U.S. 420 (establishes that routine traffic stops are investigative detentions)
Swain v. State, 181 S.W.3d 359 (appellate review of suppression rulings uses abuse-of-discretion standard)
Guzman v. State, 955 S.W.2d 85 (deference to factfinder on historical facts and credibility)
Montanez v. State, 195 S.W.3d 101 (videotape evidence may limit deference when it indisputably contradicts testimony)
Carmouche v. State, 10 S.W.3d 323 (videotape can defeat testimonial findings when it provides indisputable contrary evidence)
Zervos v. State, 15 S.W.3d 146 (officer may initiate stop on reasonable belief a traffic offense occurred)
Texas Dep’t of Pub. Safety v. Fisher, 56 S.W.3d 159 (State need only show officer reasonably believed a violation occurred, not that it actually occurred)