State v. Cameron William Varley
2016 Tex. App. LEXIS 9816
| Tex. App. | 2016Background
- Appellee Cameron Varley was charged with driving while intoxicated after an Arlington police officer stopped his pickup around 2:11 a.m. on May 23, 2013.
- Officer Gilbert observed what he believed was a brake-light violation: one rear brake light appeared inoperative; Varley’s truck had a high-mounted center brake light on the rear of the cab plus another rear lamp.
- Gilbert also observed the vehicle weave within its lane but conceded that alone would not justify a stop; he relied primarily on the perceived brake-light violation to initiate the traffic stop.
- At the suppression hearing the State argued violation of Tex. Transp. Code § 547.323 (two stoplamps and one must be rear-mounted); the trial court found no reasonable suspicion and granted Varley’s motion to suppress.
- The State appealed; on appeal the State argued (1) the trial court misinterpreted § 547.323, (2) the stop was supported by Terry-level reasonable suspicion, and (3) the officer’s reasonable but mistaken reading of the statute (or federal adoption) validated the stop under Heien.
- The appellate court reversed, holding the officer’s reasonable mistake of law made the stop lawful under Heien and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 547.323 requires two rear-mounted stoplamps | State: officer saw statutory violation (failed to have two rear stoplamps) | Varley: his truck had two working stoplamps, including one on the rear; statute ambiguous | Court: §547.323(a) requires two stoplamps overall and §547.323(c) requires one stoplamp mounted on the rear; Varley complied with both |
| Whether officer had reasonable suspicion to stop | State: totality (observed defective lamp + weaving) supported reasonable suspicion | Varley: no statutory violation shown; weaving alone insufficient | Court: even if statutory violation uncertain, officer’s reasonable legal mistake justified the stop under Heien |
| Whether the State could rely on federal standard (Tex. Transp. Code §547.3215) | State: federal standard requires two rear lamps + high‑mounted lamp, which would have clearly supported the stop | Varley: trial record did not include §547.3215; issue not preserved | Court: §547.3215 was not argued below, so State waived reliance on it on appeal |
| Whether officer’s mistaken interpretation of law can supply reasonable suspicion | State: Heien permits stop when officer’s mistake of law is objectively reasonable | Varley: Texas precedent disallowed reasonable mistakes to supply suspicion | Court: Heien controls; officer’s reasonable mistake of law rendered the stop constitutional despite contrary Texas precedents |
Key Cases Cited
- Heien v. North Carolina, 135 S. Ct. 530 (2014) (U.S. Supreme Court: an objectively reasonable mistake of law can justify a Terry stop)
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable-suspicion standard for investigative stops)
- Robinson v. State, 377 S.W.3d 712 (Tex. Crim. App. 2012) (Texas precedent rejecting reasonable-mistake-of-law as basis for suspicion)
- Amador v. State, 221 S.W.3d 666 (Tex. Crim. App. 2007) (bifurcated standard of review for suppression rulings)
- Munsey v. State, 424 S.W.3d 767 (Tex. App.—Fort Worth 2014) (State bears burden to prove reasonableness of warrantless stop)