Michael Isaac Villarreal v. State, 04-15-00593-CR

At 2:15 a.m. Officer Erik Rodriguez observed Villarreal’s car weave in and out of its lane and travel onto the shoulder while entering I-410; Rodriguez followed for ~60–90 seconds.
Rodriguez stopped the vehicle, asked for license/insurance, and detected a strong odor of alcohol, bloodshot eyes, slurred speech; Villarreal said “I’m drunk” and staggered.
Officer Rodriguez administered three standardized field sobriety tests and observed multiple clues of intoxication across those tests.
Villarreal was arrested for DWI, refused chemical testing after being warned of the consequences, and was charged by information.
Villarreal moved to suppress arguing the stop lacked reasonable suspicion (and raised other suppression theories but limited the hearing to the legality of the stop). The trial court denied the motion.
A jury convicted Villarreal of DWI; sentence was probated. Villarreal appealed solely challenging the stop as unsupported by reasonable suspicion.

Issue	Villarreal's Argument	State's Argument	Held
Whether officer had reasonable suspicion to stop for DWI	Stop was unsupported by specific, articulable facts of intoxication; weaving alone is insufficient	Repeated weaving late at night, officer experience, and duration of observation provided reasonable suspicion to stop for DWI	Stop was supported: officer reasonably suspected DWI based on weaving several times over short distance at 2:15 a.m.
Whether reasonable suspicion for a traffic offense was required	Stop invalid if no Transportation Code violation occurred	Reasonable suspicion of criminal activity (DWI) alone authorizes the stop; need not independently prove a traffic offense	Court need not reach traffic-code argument because reasonable suspicion for DWI justified the stop

Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (standard of review for suppression rulings)
Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (deference to trial court fact findings and credibility assessments)
Cole v. State, 490 S.W.3d 918 (Tex. Crim. App. 2016) (view evidence in light most favorable when no findings requested)
Curtis v. State, 238 S.W.3d 376 (Tex. Crim. App. 2007) (weaving several times late at night can supply reasonable suspicion of DWI)
Garcia v. State, 43 S.W.3d 527 (Tex. Crim. App. 2001) (reasonable-suspicion framework; totality of circumstances)
York v. State, 342 S.W.3d 528 (Tex. Crim. App. 2011) (objective standard for reasonable suspicion; officer’s subjective intent irrelevant)