Geraline Gregory Lincoln v. State, 14-14-00957-CR

Appellant Lincoln was charged in two Harris County cases: cocaine possession (>4 g, 481.115(a),(c)) in case 1424405 and unlawful possession of a firearm by a felon (46.04(a)) in case 1424406, each with punishment enhancements.
Pretrial motions to suppress were denied after a dispositive hearing on the merits; pleas of guilty and true to enhancements followed, with eight-year sentences to run concurrently under a plea agreement.
The appellate brief challenges the denials of the suppression motions, arguing the stop violated the Fourth Amendment.
Facts center on a 2014 traffic stop in North Houston after deputies observed multiple traffic infractions by Lincoln, including driving in the middle of the road and failing to signal turns; dash-cam video did not capture all infractions.
At suppression, the trial judge credited the officers’ testimony of five traffic violations and found reasonable suspicion to detain, relying on totality of the circumstances and credibility determinations.
The State contends the stop was supported by reasonable suspicion; Lincoln preserves his sole point of error regarding suppression denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the detention was supported by reasonable suspicion for a traffic stop	Lincoln contends no reasonable suspicion existed	State argues totality of circumstances supported a lawful traffic stop	Denial of suppression affirmed; stop supported by reasonable suspicion

Abney v. State, 394 S.W.3d 542 (Tex. Crim. App. 2013) (reasonable expectation for traffic-stop reasonable suspicion standard)
Miller v. State, 418 S.W.3d 692 (Tex. App.—Houston [14th Dist.] 2013) (reasonable basis for detaining for traffic offenses exists under totality of circumstances)
State v. Ross, 32 S.W.3d 853 (Tex. Crim. App. 2000) (abuse of discretion standard for suppression rulings; factual deference)
Valtierr a v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (deference to trial court findings on credibility in suppression review)
Elias v. State, 339 S.W.3d 667 (Tex. Crim. App. 2011) (objective evaluation of signaling and traffic-safety infractions supporting reasonable suspicion)
Castro v. State, 227 S.W.3d 737 (Tex. Crim. App. 2007) (trial court credibility findings favored when supported by record)
Duran v. State, 396 S.W.3d 563 (Tex. Crim. App. 2013) (almost-total deference to trial court factual findings based on credibility)
Martinez v. State, 358 S.W.3d 919 (Tex. Crim. App. 2011) (zone-of-reasonable-disagreement standard for suppression rulings)
State v. Woodard, 341 S.W.3d 404 (Tex. Crim. App. 2011) (strong deference to trial court’s credibility determinations in suppression)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (limits on deference when video indisputably contradicts officer testimony)