Joseph Sheldon Hood v. State, 11-16-00173-CR

Officers received a tip from a confidential informant that a white male with a “blue” parole warrant—described as closely shaved/bald and standing by a white Impala on the west side of the Vineyard Apartments—was present there.
Agent Cockerham and other officers went to the location, found Appellant (white, closely shaved) sitting in the only white Impala in the lot, asked him and three passengers to exit, and requested identification.
Dispatch confirmed Appellant had an outstanding warrant; officers then arrested and handcuffed him.
While in custody Appellant told officers he had controlled substances; officers recovered a black pouch from his pants zipper containing five baggies, two of which field-tested and later lab-confirmed as 5.08 grams of methamphetamine.
Appellant moved to suppress the evidence, arguing the detention/arrest and subsequent seizure violated the Fourth Amendment; the trial court granted suppression as to a search of the Impala’s trunk but denied suppression of the evidence found on Appellant’s person.
The jury convicted Appellant of possession of methamphetamine (more than four grams but less than 200 grams) with an enhancement true; punishment was 40 years’ confinement and a $10,000 fine. This appeal challenges the denial of suppression for the personal search.

Issue	Plaintiff's Argument (Hood)	Defendant's Argument (State)	Held
Whether officers had reasonable suspicion for an investigatory detention	Informant’s tip did not identify Hood by name and thus was an uncorroborated hunch insufficient for detention	Tip provided detailed descriptors and location; informant was previously reliable, so combined facts gave reasonable suspicion	Denied relief — court held informant’s specific details + prior reliability supplied reasonable suspicion
Whether the pre-arrest detention amounted to a warrantless arrest (making subsequent search invalid)	Surrounding vehicle and holding Hood until warrant confirmation constituted an arrest (citing McCraw)	The stop was brief, no weapons drawn, identification and warrant check were investigatory steps; once dispatch confirmed an active warrant, arrest was lawful and search incident to arrest valid	Denied relief — court held detention was investigatory and, after warrant confirmation, arrest and search were lawful

Terry v. Ohio, 392 U.S. 1 (establishes investigatory stop/reasonable suspicion standard)
Carmouche v. State, 10 S.W.3d 323 (confidential informant information can supply reasonable suspicion when reliability is shown)
Ford v. State, 158 S.W.3d 488 (defines reasonable suspicion in Texas context)
McCraw v. State, 117 S.W.3d 47 (distinguishes investigatory detention from arrest when force and blockage are used)
Burkes v. State, 830 S.W.2d 922 (no investigation means detention rises to arrest)
Francis v. State, 922 S.W.2d 176 (arrest involves a seizure that is not brief)
Rhodes v. State, 945 S.W.2d 115 (permissible level of force during investigative stops)
Padilla v. State, 462 S.W.3d 117 (discusses informant veracity, reliability, and basis of knowledge as relevant to reasonable suspicion)
Guzman v. State, 955 S.W.2d 85 (appellate standard of review for suppression rulings; deference to trial court on historical facts)