Gonzales v. State, 342 S.W.3d 151

Gonzales pleaded guilty to a third-degree felony DWI and received five years' confinement (suspended), a $1,000 fine, five years of community supervision, and 30 days in county jail as a condition of supervision.
Gonzales appeals the denial of his pretrial motion to suppress arguing the detention was unlawful because the officer abandoned a community caretaking purpose.
The suppression court found Officer Becker approached to check on the driver’s welfare, with a reasonable, primary community-caretaking motive.
Becker activated emergency lights and took a take-down light; Gonzales exhibited red, bloodshot eyes and there was a strong odor of alcohol.
The court concluded the initial encounter constituted a seizure and analyzed whether it was justified under the community caretaking exception.
The appellate court affirmed, holding the seizure was valid as the officer’s primary motive was to aid the driver and his belief that help was needed was reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the seizure was valid under community caretaking	Gonzales argues seizure lacked caretaking purpose and was punitive.	Gonzales contends officer primarily sought to help; caretaking was reasonable.	Seizure justified; suppression denied.

Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (deference to trial court on historical facts; mixed questions)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (standard for reviewing suppression evidence)
Corbin v. State, 85 S.W.3d 272 (Tex. Crim. App. 2002) (community caretaking exception and its limits)
Wright v. State, 7 S.W.3d 148 (Tex. Crim. App. 1999) (factors for evaluating caretaker distress and location)
State v. Garcia-Cantu, 253 S.W.3d 236 (Tex. Crim. App. 2008) (blue lights can constitute a detention; objective behavior governs seizure)