Sara Joyce Ellen Buendia v. State, 04-16-00705-CR

Deputy Roseland observed Buendia at an intersection and later stopped her after seeing her drive onto the unimproved right shoulder and make a right turn into a mobile home park.
Roseland testified he stopped Buendia primarily because she failed to stop at a clearly marked stop line at the intersection; he did not activate his dash camera before that stop and the video does not show the intersection stop.
During the stop Roseland observed small plastic bags in the door, learned Buendia had prior felony drug arrests, and Buendia made statements suggesting someone might have left meth in the car; she refused consent to search.
A canine unit arrived, the dog alerted to the driver’s side and the plastic bags, and Roseland then searched the vehicle and found 38 grams of methamphetamine; Buendia was arrested.
At suppression hearings, Roseland testified a white stop line existed at the intersection; the trial court reviewed Google Earth images and photographs and found a stop line existed and that Roseland had reasonable suspicion to stop Buendia.
The trial court denied the motion to suppress; Buendia pled guilty and appealed, arguing the stop lacked reasonable suspicion because the dash camera did not show the alleged failure to stop.

Issue	Buendia's Argument	State's Argument	Held
Whether deputy had reasonable suspicion to stop vehicle	Dash cam does not show failure to stop; no evidence of violation	Officer observed stop line violation and reasonably believed offense occurred	Trial court credited officer; stop was supported by reasonable suspicion
Whether officer needed to tell Buendia the specific basis for the stop	Officer told her he stopped her for driving on shoulder, not for failing to stop	Officer need not identify specific offense; objective facts suffice	Not required; officer’s subjective statement irrelevant to objective reasonable suspicion
Whether dash cam silence undermines officer credibility	Video doesn’t capture the alleged stop; undermines claim that stop occurred	Officer testified he observed violation before activating camera; court may credit testimony	Court deferred to trial court’s credibility finding in favor of officer
Whether driving on shoulder justified the stop	Buendia contends driving on shoulder was lawful when making a right turn	Officer testified he believed shoulder driving was a violation and that main reason was failure to stop	Court noted shoulder driving admission but relied on failure-to-stop finding as basis for reasonable suspicion

Jaganathan v. State, 479 S.W.3d 244 (Tex. Crim. App. 2016) (reasonable-suspicion standard for traffic stops)
Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (objective standard—officer’s subjective intent disregarded)
Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (totality of circumstances; officer need not pinpoint specific crime)
Castro v. State, 373 S.W.3d 159 (Tex. App.—San Antonio 2012) (deference to trial court fact findings on suppression)
Valtierra v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (trial judge as sole trier of credibility)