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Robert Lafayette Walker v. State
12-15-00128-CR
| Tex. App. | Aug 17, 2015
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Background

  • Walker challenged the denial of his motion to suppress in a DWI-2nd Offense case; he pled guilty after suppression denial and was sentenced to 200 days in jail; appeal timely filed.
  • Motion focused on whether the trooper had probable cause to stop based on videotape; trooper testified to crossing the double-yellow line, but video did not clearly show it.
  • Anonymous DPS 911 tip purportedly reporting a drunk driver, but the DPS 911 tape was not produced and the tip lacked corroboration.
  • The videotape allegedly contradicted the trooper’s account; the trial court did not rely on the video to sustain the stop.
  • Appellant argues the stop was not justified by any observed traffic violation or corroborated tip, warranting suppression and acquittal.
  • Court considered whether the videotape can negate officer credibility and whether anonymous tips can justify stops without corroboration.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Does the videotape negate the trooper’s testimony on the traffic stop? Walker State Yes; video contradicts the stop, warranting reversal.
Was the anonymous 911 tip sufficient to justify detention? Walker State No; tip uncorroborated, insufficient for stop.
Did the anonymous caller provide a sufficiently detailed description? Walker State No; tip lacked detail to justify stop.

Key Cases Cited

  • Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (video can contradict officer testimony; deference limits when video is indisputable)
  • Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (deference to trial court on factual findings; credibility determinations)
  • State v. Ballard, 987 S.W.2d 889 (Tex. Crim. App. 1999) (standard for suppression appeals; appellate review of historical facts)
  • Montanez v. State, 195 S.W.3d 101 (Tex. Crim. App. 2006) (videotape as evidentiary aid in suppression rulings)
  • State v. Weaver, 349 S.W.3d 521 (Tex. Crim. App. 2011) (deference to trial court on credibility in suppression)
Read the full case

Case Details

Case Name: Robert Lafayette Walker v. State
Court Name: Court of Appeals of Texas
Date Published: Aug 17, 2015
Docket Number: 12-15-00128-CR
Court Abbreviation: Tex. App.