Robert Spaeth v. State
07-15-00395-CR
| Tex. App. | Oct 18, 2017Background
- Shortly after midnight on Jan. 21, 2015, Spaeth (Appellant) made a U-turn at the intersection of E Amarillo Blvd and N Johnson St. and was stopped by Officer Serbantez.
- Officer observed the turn, stopped Appellant for allegedly making a U-turn in a “business district,” and conducted a warrantless vehicle search that recovered <2 ounces of marijuana.
- Appellant moved to suppress; parties submitted stipulated facts (including that the U-turn was made at an intersection, safely, without interfering with traffic, and not at a signalized intersection). The motion was denied and Appellant pled guilty under a plea bargain.
- The sole legal question was whether the stop was lawful under Amarillo Municipal Code §16-3-133, which prohibits U-turns in a “business district.” Section 16-3-132 permits U-turns at intersections if done safely and not interfering with traffic.
- Trial court took judicial notice that the intersection had commercial uses on two corners and commercial lots on the other two, and that zoning classified the intersection as “light commercial.”
- Court of Appeals affirmed, holding the ordinance’s term “business district” was not unconstitutionally vague and that the stop was lawful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was lawful because the U-turn violated §16-3-133 (U-turns prohibited in a “business district”) | Spaeth: §16-3-133 is ambiguous/vague — “business district” either means the narrowly defined “Central Business District” or is undefined and vague; vagueness violates fair notice and the rule of lenity | State: “business district” means any business/commercial zoning area (not limited to the Central Business District); ordinary meaning and zoning map give fair notice; statute is not vague | Held: Court rejects Spaeth’s vagueness argument, concludes §16-3-133 applies to the intersection (zoned commercial), so the stop was lawful |
Key Cases Cited
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (reasonable-suspicion/totality-of-circumstances standard for brief investigatory stops)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (burden on State to show reasonable suspicion for investigatory detention)
- Grayned v. City of Rockford, 408 U.S. 104 (U.S. 1972) (vagueness/fair notice principles for criminal statutes)
- Furr v. State, 499 S.W.3d 872 (Tex. Crim. App. 2016) (standard of review for suppression hearings)
- Cole v. State, 490 S.W.3d 918 (Tex. Crim. App. 2016) (deference to trial court’s fact findings in suppression rulings)
- Holcombe v. State, 187 S.W.3d 496 (Tex. Crim. App. 2006) (undefined statutory terms are given their ordinary meaning and are not automatically vague)
- Watson v. State, 369 S.W.3d 865 (Tex. Crim. App. 2012) (dictionary meanings may supply ordinary meaning for undefined statutory terms)
- Meuret v. State, 500 S.W.3d 539 (Tex. Crim. App. 2016) (interpretive principles for statutory language and ordinary meaning)