James E. Saldana v. State, 04-14-00658-CR

Background

On June 26, 2011, Officer Christopher Torres heard a loud bang, observed Saldana’s pickup exit a parking lot and stop ‘‘somewhat in the middle of the roadway,’’ and saw Saldana and a passenger inspecting the rear of the truck late at night.
Torres activated his patrol vehicle emergency lights, exited, and approached to perform a welfare check to see if the vehicle was damaged or occupants needed assistance.
During the contact Torres detected signs of intoxication and conducted a DWI investigation; the State stipulated the arrest was warrantless.
Saldana moved to suppress evidence, arguing the encounter was an unlawful seizure; the trial court denied the motion and later issued written findings.
Saldana pled guilty to DWI and appealed the denial of the suppression motion; the State argues the stop was lawful under the community‑caretaking exception.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer’s contact was a seizure requiring reasonable suspicion/probable cause	Saldana: activating lights and approaching converted contact into a seizure requiring justification	State (Torres): encounter was a noninvestigatory welfare check under community‑caretaking, not a seizure needing suspicion	Court upheld trial court: the encounter was justified under community‑caretaking and denial of suppression was not an abuse of discretion
Whether officer was primarily motivated by community‑caretaking purpose	Saldana: officer’s actions were investigative (DWI) and therefore primarily law‑enforcement motivated	State: officer’s testimony and facts (loud bang, vehicle stopped in roadway, occupants inspecting truck) show primary motive was welfare check	Court deferred to trial court credibility findings and found officer primarily motivated by caretaking
Whether officer reasonably believed the occupants needed help	Saldana: facts insufficient to show reasonable belief of need for assistance	State: late hour, vehicle stopped in middle of road, occupants inspecting rear after loud bang made belief reasonable	Court held belief was reasonable under totality of circumstances and Wright guidance
Whether activating emergency lights automatically escalates encounter into detention	Saldana: use of lights turns a contact into a stop	State: use of lights to illuminate/check on a possibly disabled/damaged vehicle does not necessarily convert to a detention	Court concluded use of lights did not necessarily escalate the encounter and accepted trial court’s ruling

Key Cases Cited

Cady v. Dombroski, 413 U.S. 433 (1973) (established community‑caretaking exception to warrant requirement)
Wright v. State, 7 S.W.3d 148 (Tex. Crim. App. 1999) (officer may stop to assist if a reasonable person would believe help is needed; factors to evaluate reasonableness)
Gonzales v. State, 369 S.W.3d 851 (Tex. Crim. App. 2012) (two‑prong test: primary caretaking motive and reasonable belief of need; Wright factors are guidance, not elements)
Solano v. State, 371 S.W.3d 593 (Tex. App.—Amarillo 2012) (affirmed community‑caretaking justification where vehicle showed signs of trouble)
Kuykendall v. State, 335 S.W.3d 429 (Tex. App.—Beaumont) (affirmed welfare check stop for vehicle parked in dark area with parking lights on)
Corbin v. State, 85 S.W.3d 272 (Tex. Crim. App. 2002) (community‑caretaking not available where primary motive was non‑caretaking law enforcement)
Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (standards for appellate review of factual findings and credibility)
Martinez v. State, 348 S.W.3d 919 (Tex. Crim. App. 2011) (abuse‑of‑discretion standard for suppression rulings)
Amador v. State, 221 S.W.3d 666 (Tex. Crim. App. 2007) (bifurcated review for suppression rulings)
Valtierra v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (view evidence in light most favorable to trial court's ruling)
Miller v. State, 393 S.W.3d 255 (Tex. Crim. App. 2012) (deference to trial court on historical facts and credibility)