State v. Mendoza
2012 Tex. Crim. App. LEXIS 646
| Tex. Crim. App. | 2012Background
- Police stopped Mendoza based on observed weaving and braking; Officer Davila testified Mendoza was weaving, veering right, and braking erratically.
- Trial court granted suppression, finding no reasonable suspicion; dash-cam video showed no clear traffic offense.
- Court of Appeals inferred the trial court credited the officer's version; held ruling could be correct if the officer’s version supported reasonable suspicion.
- Texas Court of Criminal Appeals granted review to evaluate if appellate court properly deferred to trial court's factual findings without implicit credibility determinations.
- Court found written findings ambiguous and lacking explicit credibility determinations; remanded to abate to the trial court for supplemental findings.
- Opinion emphasizes that trial judge is sole arbiter of historical facts and credibility; de novo review applies to law, not facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do ambiguous trial findings require remand for explicit credibility determinations? | Mendoza | Davila | Remanded for supplemental explicit findings |
| Should appellate review defer to trial court facts and credibility in suppression rulings? | Mendoza | State | Defer to trial court on historical facts; review legal conclusions de novo |
| May appellate court resolve the suppression ruling by crediting officer testimony based on the record? | Mendoza | State | Not if factual credibility is ambiguous; require clarifying findings |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reasonable suspicion standard is mixed law and fact; review de novo on law)
- State v. Cullen, 195 S.W.3d 696 (Tex.Crim.App. 2006) (require explicit findings of fact in suppression rulings)
- State v. Elias, 339 S.W.3d 667 (Tex.Crim.App. 2011) (remand when findings are insufficient to resolve legal issue)
- State v. Ross, 32 S.W.3d 853 (Tex.Crim.App. 2000) (preserve ability to infer implied findings consistent with ruling)
- Wiede v. State, 214 S.W.3d 17 (Tex.Crim.App. 2007) (defer to trial judge’s credibility and factual determinations)
- Crain v. State, 315 S.W.3d 43 (Tex.Crim.App. 2010) (totality of circumstances as the basis for reasonable suspicion)