State v. Lindsey Nichole Houghton
2012 Tex. App. LEXIS 8881
| Tex. App. | 2012Background
- The State appeals from the trial court’s written order suppressing evidence from a traffic stop of Lindsey Houghton.
- Houghton was charged with driving while intoxicated and moved to suppress the stop’s evidence.
- Officer Mark Epps testified at a suppression hearing and his in-car video was viewed by the court.
- The officer claimed Houghton’s driving showed weaving, left-of-center movement, and slow speed after initial observation.
- The trial court found Epps’ credibility lacking and suppressed the stop as unlawful detention.
- On review, the court deferred to the trial court’s credibility findings and affirmed the suppression order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop supported by reasonable suspicion? | Houghton | Houghton | No; no specific articulable facts showed reasonable suspicion. |
| Did observed driving maneuvers amount to traffic violations justifying the stop? | State | Houghton | No; video did not clearly show a violation; safe, non-unsafe conduct weakened the basis for stop. |
Key Cases Cited
- Amador v. State, 221 S.W.3d 666 (Tex. Crim. App. 2007) (deferential standard on suppression rulings; historical facts favored to trial court)
- Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (framework for suppression review)
- Wiede v. State, 214 S.W.3d 17 (Tex. Crim. App. 2007) (deference to credibility determinations in fact-based rulings)
- Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (indisputable video evidence may override trial findings)
- Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (requires articulable facts supporting traffic stop)
- Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (totality-of-circumstances under Terry standard)
- Martinez v. State, 348 S.W.3d 919 (Tex. Crim. App. 2011) (reasonableness measured by what officer knew before stop)
- Johnson v. State, 68 S.W.3d 644 (Tex. Crim. App. 2002) (clarifies reasonable suspicion standard)
- State v. Ross, 32 S.W.3d 853 (Tex. Crim. App. 2000) (credibility and fact-finding in suppression)
- Carter v. State, 309 S.W.3d 31 (Tex. Crim. App. 2010) (video facts and deference to trial court’s findings)