State v. Isaac Sastaita, 13-14-00237-CR

Kingsville police stopped Isaac Sastaita for speeding; Officer Martinez observed Sastaita trembling, pale, and extremely nervous while issuing a citation.
Martinez called for backup (Officer Daniel Gonzalez). Gonzalez arrived ~3–4 minutes later, spoke with Sastaita, noted continued extreme nervousness, changes in voice, and a self “pat‑search” motion.
Gonzalez asked about drugs/weapons; Sastaita became more nervous and refused consent to search; Gonzalez then told him he was being detained pending a canine unit, after which Sastaita admitted there was marijuana in the vehicle and was arrested.
Sastaita moved to suppress the statement and evidence, arguing the traffic stop was unlawfully prolonged without reasonable suspicion of additional criminal activity.
Trial court granted suppression, entered findings concluding officers conducted a “fishing expedition” and unlawfully prolonged the stop; State appealed. Appellate court reviewed de novo whether facts supported reasonable suspicion to extend the stop.
Appellate court held officers’ cited grounds (nervousness, odd behavior/self‑pat down, and an unproven lie about criminal history) were insufficient to create reasonable suspicion to prolong the detention; suppression affirmed.

Issue	State's Argument	Sastaita's Argument	Held
Was the traffic stop lawfully prolonged based on reasonable suspicion of additional criminal activity?	Officer Gonzalez had specific, articulable facts (extreme nervousness, deceptive behavior, prior drug arrest/lying) justifying continued detention and request for canine.	The stop was completed after citation issuance; officers lacked reasonable suspicion to detain further — the questioning was a fishing expedition.	The appellate court held the post‑citation detention was not supported by reasonable suspicion; nervousness and the described "odd behavior" were insufficient. Suppression affirmed.

Mapp v. Ohio, 367 U.S. 643 (Exclusionary rule applies to states)
Terry v. Ohio, 392 U.S. 1 (Scope of investigative stops)
Wade v. State, 422 S.W.3d 661 (reasonable suspicion review; fruit of poisonous tree for prolongation)
Davis v. State, 947 S.W.2d 240 (stops cannot be fishing expeditions)
Garcia v. State, 43 S.W.3d 527 (reasonable suspicion requires specific, articulable facts)
Kothe v. State, 152 S.W.3d 54 (diligent pursuit standard for length of Terry stops)
Crain v. State, 315 S.W.3d 43 (abuse of discretion standard for suppression rulings)