State of Texas v. Story, Kimberly Crystal, 2014 Tex. Crim. App. LEXIS 1563

Anonymous call reported a vehicle in a field chasing a male; deputies found an SUV in the field and Kuykendall nearby.
Kuykendall was brought back to the scene; Story appeared; they stated they were arguing and nothing had happened.
A deputy saw what appeared to be marijuana in plain view on the front passenger floorboard and arrested Kuykendall after he admitted ownership.
Deputies seized marijuana and, during a search of the vehicle, found several checks in the back seat related to Story/Youth Livestock Show.
Story was indicted for forgery; a suppression motion was granted based on lack of probable cause, trespass, and illegality of the seizure; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the checks were tainted as fruit of an unlawful arrest	Story	State	Yes, suppression proper
Whether the search was valid under Kuykendall's arrest or open-field doctrine	Story	State	Open-field theory not properly raised; search not valid under Kuykendall’s arrest; suppression affirmed
Whether Story’s arrest lacked probable cause based on anonymous tip and argument context	Story	State	Arrest unlawful due to lack of probable cause; suppression affirmed

Neal v. State, 256 S.W.3d 264 (Tex. Crim. App. 2008) (probable cause and search-incident doctrine standards in automobile context)
Rojas v. State, 797 S.W.2d 41 (Tex. Crim. App. 1990) (anonymous tip alone cannot supply probable cause for search/arrest)
Amores v. State, 816 S.W.2d 407 (Tex. Crim. App. 1991) (requires additional facts beyond an anonymous tip for probable cause)
Oliver v. United States, 466 U.S. 170 (1984) (open fields doctrine as to privacy expectations)
Wong Sun v. United States, 371 U.S. 471 (1973) (taint analysis for evidence obtained from unlawful search)
State v. Ballard, 987 S.W.2d 889 (Tex. Crim. App. 1999) (limits on when a warrantless search incident to arrest is permissible)