State v. Woodard
2011 Tex. Crim. App. LEXIS 447
| Tex. Crim. App. | 2011Background
- Woodard drove off the road into a ditch and walked away, later challenging a warrantless DWI arrest a quarter-mile from the scene.
- An anonymous tip alleged a single-vehicle accident; officers headed to the scene and separately encountered Woodard on a nearby sidewalk.
- Officer Warner, believing Woodard matched the tipster’s description, stopped him and asked if he had been involved in the accident; Woodard admitted involvement and intoxication.
- Officer Morgan found an unoccupied wrecked car with alcohol containers; this supported suspicion of intoxication and potential driving while intoxicated.
- Woodard submitted to field sobriety tests and breath testing; after results, Warner arrested him for misdemeanor DWI; suppression motion followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the initial encounter consensual or a seizure? | State; initial stop was consensual, not a seizure. | Woodard; the stop was a detention/unreasonably seizure. | Consensual encounter; no Fourth Amendment seizure at initial contact. |
| Did probable cause/reasonable suspicion justify detention and arrest under Article 14.01(b)? | Woodard’s admission, odor of alcohol, eye condition, and car evidence provided probable cause or at least reasonable suspicion. | No officer witnessed an offense; arrest lacking probable cause. | Detention supported by reasonable suspicion; arrest for DWI supported by probable cause. |
| Does the anonymous tip undermine or contribute to the justification for detention/arrest? | Tip contributed to reasonable suspicion supporting detention and investigation. | Tip alone lacked credibility and could not justify detention. | Tip credibility weighed in totality of circumstances; combined with observations, it supported reasonable suspicion/probable cause. |
| May an arrest for DWI be sustained under public intoxication theory even if DWI-specific facts are not observed? | State may rely on DWI facts and surrounding circumstances to justify arrest. | Arrest should rely on DWI-specific observable conduct; not supported by record. | Court rejected reliance on public intoxication theory as primary basis; valid DWI arrest based on totality of circumstances. |
Key Cases Cited
- Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consent-based encounters and seizure analysis in police-citizen interactions)
- Brendlin v. California, 551 U.S. 249 (U.S. 2007) (ffects of traffic stops on passengers and seizure framework)
- Crain v. State, 315 S.W.3d 43 (Tex. Crim. App. 2010) (detention standards and burden shifting in suppression rulings)
- Amador v. State, 275 S.W.3d 872 (Tex. Crim. App. 2009) (probable cause and reasonable suspicion standards in Fourth Amendment analysis)
- Garcia-Cantu v. State, 253 S.W.3d 236 (Tex. Crim. App. 2008) (summary of standards for reviewing suppression motions)
- Beverly v. State, 792 S.W.2d 103 (Tex. Crim. App. 1990) (reliance on information from others and evidence governing reasonable suspicion)