Raymond McKinney v. State, 444 S.W.3d 128

McKinney, in a high-crime neighborhood, was talking on a street when a marked patrol car turned onto the street and he ran about 100 yards away.
Officers pursued, detained, and searched McKinney, yielding crack cocaine and pills; McKinney was then placed in a patrol car.
McKinney faced a suppression motion arguing the detention/search violated Fourth Amendment rights; trial court denied, and he was convicted of possessing cocaine.
Officer testimony described the area’s crime, McKinney’s flight, and the subsequent discovery of drugs; one officer later learned of an outstanding warrant for McKinney.
Defense witness claimed McKinney did not run and that the officer concealed himself behind a bush; suppression hearing occurred before the jury.
The court ultimately reversed and remanded for a new trial, holding the detention violated the Fourth Amendment and taint could not be dissipated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the initial detention was lawful under the Fourth Amendment	McKinney argues flight from a distance and high-crime area do not create reasonable suspicion	State contends pursuit was warranted by suspicious conduct and area conditions	Detention unlawful; suppression required
Whether presence in a high-crime area and flight upon seeing police justify detention	McKinney’s presence and flight alone do not justify detention	State relies on crime context to support detention	Insufficient to justify investigatory detention
Whether discovery of an outstanding warrant attenuates the taint from the illegal detention	Attenuation may not dissipate taint given unlawful stop	Warrant discovery could sever the causal link between illegality and evidence	Waiver of taint not established; taint not dissipated
Whether the taint from the illegal detention contaminated the evidence and the conviction	Illegally obtained drugs and statements contributed to conviction	Evidence would have been admissible absent illegality	Constitutional violation; reversal remanded for new trial

Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (deference to trial court on findings; suppression when illegally obtained evidence)
Mazuca v. State, 375 S.W.3d 294 (Tex. Crim. App. 2012) (attenuation of taint after illegal stop; factors: proximity, intervening circumstances, purposefulness)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (continued seizure must be supported by specific, articulable facts)
Reyes v. State, 899 S.W.2d 319 (Tex. App.—Houston [14th Dist.] 1995) (flight in high-crime area; absence of reasonable suspicion)
Gurrola v. State, 877 S.W.2d 300 (Tex. Crim. App. 1994) (detention in high-crime area—flight as factor)
Castillo v. State, No. 04-10-00893-CR, 2011 WL 4830168 (Tex. App.—San Antonio 2011) (flight alone not sufficient for detention in high-crime area)