State v. Wilson
337 S.W.3d 289
| Tex. App. | 2011Background
- State appeals a trial court ruling suppressing evidence from Wilson's arrest for possession of methamphetamine (4+ but <200 grams).
- Officer Brownlow received an anonymous tip predicting a gold Chevy Blazer with two females carrying about four ounces of methamphetamine, eastbound on Highway 66 within 15 minutes.
- Brownlow located a gold Blazer, followed it five minutes, and stopped it as it pulled into a private driveway; the driver Rossignol exited and Wilson accompanied, with the Blazer stopping before another vehicle.
- Wilson appeared to reach into her pants; officer instructed her to place hands out, and she voluntarily retrieved methamphetamine from her pants, leading to her arrest.
- Wilson moved to suppress, arguing the stop was an unlawful investigative detention lacking reasonable suspicion; the State argued it was a consensual encounter or supported by corroborated anonymous tip.
- The appellate court ultimately affirmed the suppression ruling, holding the detention lacked reasonable suspicion and the tip was not sufficiently corroborated prior to the stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Brownlow's stop an investigative detention requiring reasonable suspicion? | State: encounter was permissible without probable cause/suspicion. | Wilson: stop was a seizure needing reasonable suspicion, and not consent-based. | Detention was an investigative stop requiring reasonable suspicion. |
| Was the anonymous tip sufficiently corroborated to create reasonable suspicion? | State: Donahue's tip was corroborated by details and reliability. | Wilson: corroboration was of innocent details; not enough for reasonable suspicion. | Tip not sufficiently corroborated prior to initiation; insufficient for reasonable suspicion. |
| Did other evidence after initiation validate reasonable suspicion? | State relied on house description and other circumstantial factors as corroboration. | Wilson: other evidence did not raise reasonable suspicion; contested occupancy and area context. | Additional evidence failed to establish reasonable suspicion; detention still unlawful. |
Key Cases Cited
- Adams v. Williams, 407 U.S. 143 (U.S. 1972) (anonymous tips and reliability standards for stops)
- Florida v. Royer, 460 U.S. 491 (U.S. 1983) (consensual encounters and seizures analysis)
- J.L. v. State, 529 U.S. 266 (U.S. 2000) (corroboration and reliability of anonymous tips)
- Gurrola v. State, 877 S.W.2d 300 (Tex. Crim. App. 1994) (encounter versus seizure framework in Texas)
- Tanner v. State, 228 S.W.3d 852 (Tex.App.-Austin 2007) (initially unlawful stop not cured by later discovery)
- Garcia v. State, 43 S.W.3d 527 (Tex.Crim.App. 2001) (corroboration limitations for anonymous tips)
- Guthrie v. State, 10 S.W.3d 323 (Tex.Crim.App. 2000) (mixed questions of law and fact in suppression)