Patricia Ann Haines v. State
04-16-00410-CR
| Tex. App. | Apr 26, 2017Background:
- Investigator David Camacho observed Patricia Haines stop her truck at a red light and believed the front driver-side tire entered the crosswalk.
- Camacho activated his patrol car lights and stopped Haines; he asked for ID, insurance, origin, and arrest history.
- Haines admitted a prior meth arrest and told Camacho she had a pink bag of methamphetamine in the driver-side door pocket.
- Dash-cam video (mounted on passenger side) was admitted but did not clearly show whether Haines stopped short of the crosswalk; Camacho testified he could see more from his vantage point.
- Haines moved to suppress the drugs and statements, arguing the stop lacked reasonable suspicion because the video did not establish a traffic violation.
- The trial court credited Camacho’s testimony, denied suppression, Haines pleaded guilty and received deferred adjudication; this appeal followed.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was supported by reasonable suspicion | Haines: Video does not show she failed to stop before entering the crosswalk, so no traffic violation and no reasonable suspicion | State/Camacho: Officer personally observed the front driver-side tire enter the crosswalk and had reasonable suspicion to stop | Court: Credited officer’s testimony; reasonable suspicion existed and suppression was properly denied |
Key Cases Cited
- Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (standard of review for suppression rulings is bifurcated)
- Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (trial judge’s fact findings and credibility determinations are afforded great deference)
- Valtierra v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (trial judge is sole trier of fact and judge of witness credibility)
- Jaganathan v. State, 479 S.W.3d 244 (Tex. Crim. App. 2016) (reasonable suspicion standard for warrantless traffic stop)