Joseph Lewis Gonzales v. State, 07-15-00039-CR

In the early morning, a supervising Amarillo officer observed Gonzales turn from Georgia Street into a private parking lot without signaling.
Officers (a trainee driver, the supervising officer, and later a backup) approached Gonzales’ parked car in the dark lot; the trainee used a spotlight and asked for ID.
The supervising officer asked about weapons; Gonzales said he had a knife and reached for his pocket, prompting an officer to grab his hand.
Gonzales consented to a search of his person; officers found a tobacco can containing a mint tin with a clear bag of suspected methamphetamine.
Gonzales was handcuffed, Mirandized, gave recorded oral and written statements, and officers later inventoried his vehicle finding marijuana, a pipe, and scale residue; a background check revealed a parole-warrant and suspended license.
Gonzales moved to suppress the physical evidence and statements as the product of an unlawful detention; the trial court denied suppression, he pleaded guilty reserving the right to appeal the suppression ruling, and was sentenced to 15 years.

Issue	Gonzales' Argument	State's Argument	Held
Whether police detention was an investigatory stop (requiring reasonable suspicion) or a consensual encounter	The encounter was not a traffic stop and occurred in a private lot, so a reasonable person would not feel free to leave; detention unlawful, evidence should be suppressed	Supervising officer personally observed a traffic violation (failure to signal) giving probable cause to stop/detain; officers lawfully questioned and received consent to search	Court affirmed: under appellate review of suppression, the record reasonably supports the trial court’s implicit finding that officer observed traffic violation and detention/search were lawful
Whether consent to search and resulting evidence/statements were admissible	Evidence and statements flowed from unlawful detention and must be suppressed	Consent to search was given; contraband discovered and statements were properly Mirandized and recorded; evidence admissible	Court affirmed denial of suppression: search consent and subsequent seizure/statements upheld as properly obtained

Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (standard of appellate review for suppression rulings)
Wyatt v. State, 23 S.W.3d 18 (Tex. Crim. App. 2000) (deference to trial court fact findings; law-application reviewed de novo)
St. George v. State, 237 S.W.3d 720 (Tex. Crim. App. 2007) (trial judge as sole arbiter of witness credibility at suppression hearing)
Villarreal v. State, 935 S.W.2d 134 (Tex. Crim. App. 1996) (trial court better positioned to assess witness credibility)
Brown v. Illinois, 422 U.S. 590 (U.S. 1975) (arrests supported by probable cause)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (reasonable-suspicion standard for investigatory stops)
Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consensual encounters in public and when a person is seized)
United States v. Drayton, 536 U.S. 194 (U.S. 2002) (officers may approach and question in public absent coercion; seizure depends on whether a reasonable person would feel free to leave)
State v. Kurtz, 152 S.W.3d 72 (Tex. Crim. App. 2004) (distinguishing traffic arrests from other investigative detentions)