Lujan v. State
2011 Tex. Crim. App. LEXIS 2
| Tex. Crim. App. | 2011Background
- Lujan was stopped at a stationary checkpoint targeting uninsured and unlicensed drivers; a K-9 unit was present.
- Driver lacked a valid license; passenger had no ID but disclosed a name and later had warrants.
- During a citation process, deputies learned of warrants and conducted a pat-down, where large cash was found.
- A drug-sniffing dog alerted to drugs hidden in the vehicle; discovery occurred within six to seven minutes of the stop.
- Trial court denied the motion to suppress; on appeal, the court of appeals reversed, finding the checkpoint was not solely for licenses/insurance.
- This Court granted review to decide whether the checkpoint’s primary purpose was license/insurance verification or general crime enforcement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the checkpoint's primary purpose license/insurance or general crime control? | Lujan: checkpoint primarily for general crime control. | State: checkpoint's primary purpose was license and insurance verification. | Primary purpose was license/insurance; suppression denied. |
| Did the appellate court err by rejecting the trial court's implicit findings of fact? | Lujan: trial court implicitly found permissible license/insurance purpose. | State: court of appeals properly scrutinized conflicting testimony. | Court of appeals erred; implicit findings supported by record; reversal of that ruling. |
| Does the presence of a K-9 undermine the license/insurance primary purpose? | Lujan: dog and other duties suggest general enforcement; improper checkpoint. | State: dog was part of unit but not necessarily primary purpose; permissible focus on licenses. | Dog presence does not negate a license/insurance primary purpose when supported by trial court findings. |
| May officers act on information learned during a checkpoint stop that arises incident to the permissible primary purpose? | Lujan: any further action beyond license/insurance is improper. | State: Edmond allows acting on information discovered during a valid checkpoint stop. | Edmond permitted; officers may act on information arising during a permissible checkpoint stop. |
Key Cases Cited
- City of Indianapolis v. Edmond, 531 U.S. 32 (U.S. 2000) (checkpoints must have a primary purpose of license/registration; not for general crime detection)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (unreasonable to stop motorists without reasonable cause solely to check licenses)
- Guzman v. State, 955 S.W.2d 85 (Tex.Crim.App. 1997) (standard for reviewing suppression rulings; implicit findings given deference)
- State v. Ross, 32 S.W.3d 853 (Tex.Crim.App. 2000) (mixed questions of fact and law; deference to trial court on credibility)