Matthews, Cornelious L.
2014 Tex. Crim. App. LEXIS 820
| Tex. Crim. App. | 2014Background
- Matthews charged with possession with intent to deliver cocaine; pre-trial suppression contested; a warrantless search of a borrowed van yielded crack cocaine and marijuana; initial detention based on anonymous tip and later corroboration; Matthews fled officers, leading to pursuit and continued detention; K-9 sweep resulted in seizure of drugs; trial court and court of appeals found lack of standing in some rulings; Texas Court of Criminal Appeals granted review to decide standing in borrowed-vehicle searches and reasonableness of detention.
- Matthews fled the scene, abandoning the van and his privacy interest, affecting standing to challenge the van search.
- Officers relied on more than the anonymous tip for detention; corroboration of the tip and circumstances supported reasonable suspicion; flight enhanced suspicion and justified awaiting a drug dog.
- Court held Matthews initially had standing to challenge the van search but abandoned privacy interest by fleeing; detention was reasonable under totality of circumstances.
- Judgment affirmed—standing to challenge van search was abandoned upon flight; detention supported by reasonable suspicion; search of van upheld.
- Procedural posture included suppression motions, and ultimate appellate affirmance of the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to challenge borrowed-vehicle search | Matthews had privacy in borrowed van | Borrower lacks standing if no dominion | Standing abandoned by flight; search upheld. |
| Reasonable suspicion for initial detention | Detention based solely on anonymous tip | Totality supports reasonable suspicion | Detention reasonable; dog sniff pending did not violate Fourth Amendment. |
Key Cases Cited
- Florida v. J.L., 529 U.S. 266 (2000) (anonymous tips require reliability for reasonable suspicion)
- United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion standard for detention)
- Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (framework for reasonable suspicion and totality of circumstances)
- Wade v. State, 422 S.W.3d 661 (Tex. Crim. App. 2013) (diligent pursuit of investigation informs stop duration)
- Rakas v. Illinois, 439 U.S. 128 (1978) (standing requires personal privacy interest)