Juan Alejandro Valderama v. State, 01-15-00508-CR

Student Juan Alejandro Valderama (12th grade) was seen during class hours with another student (Castillo) and former student Summerall by a PISD police officer at the open trunk of Summerall’s car in front of the school; Summerall handed Valderama a binder and then drove away.
Officer Rodriguez escorted Valderama and Castillo to Assistant Principal (AP) John Thompson’s office for questioning for being outside during class (truancy); Castillo was defensive and later searched, revealing a small amount of marijuana.
Based on Rodriguez’s observations (exchange at car, Summerall’s known drug use shown on social media) and Castillo’s positive test, Thompson searched Valderama and then his binder after a secretary reported Valderama had been nervous and placed the binder under his chair.
Thompson found a wallet in the binder containing a small plastic bag of cocaine; the substance field-tested positive. Valderama moved to suppress the evidence; the trial court denied the motion.
Valderama pleaded guilty with deferred adjudication and community supervision; he appealed solely arguing the search of his binder/wallet was not reasonably related in scope to the truancy-related detention.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the search of Valderama’s binder/wallet violated the Fourth Amendment (school-search reasonableness under T.L.O.)	Valderama: Search exceeded scope of truancy-related intrusion because no direct link between truancy and contraband in binder	State/School: Officer’s observations (exchange at trunk, Summerall’s drug reputation), Castillo’s defensiveness and marijuana finding, and Valderama’s evasive/nervous behavior gave reasonable suspicion to search binder	Court: Search was reasonable; justified at inception and reasonably related in scope to suspected drug possession; suppression denied

New Jersey v. T.L.O., 469 U.S. 325 (U.S. 1985) (establishes student-search standard: reasonable at inception and reasonable in scope)
Coronado v. State, 835 S.W.2d 636 (Tex. Crim. App. 1992) (searches beyond the scope of truancy suspicion can be excessively intrusive)
Hamal v. State, 390 S.W.3d 302 (Tex. Crim. App. 2012) (nervousness and criminal history are factors but not alone dispositive for reasonable suspicion)
Turrubiate v. State, 399 S.W.3d 147 (Tex. Crim. App. 2013) (standard of review for suppression rulings: defer to trial court fact findings; legal application reviewed de novo)
Gonzales v. State, 369 S.W.3d 851 (Tex. Crim. App. 2012) (deference to trial court on credibility and historical facts at suppression hearings)