Valadez, Alvin Jr., PD-1308-15

On Aug. 28, 2012 a Guadalupe County justice of the peace issued an arrest warrant charging Alvin Valadez Jr. with engaging in organized criminal activity (underlying offense: aggravated assault). A five‑page complaint/affidavit by Detective Clint Halbardier supported the warrant.
Halbardier’s affidavit relied on four unnamed witnesses (two described as previously reliable or with gang‑connected acquaintances, one eyewitness who corroborated the victim, and one with no criminal history), the victim’s hospital statement, local offense reports, and database information identifying Valadez as a documented Mexican Mafia lieutenant.
Sheriff’s investigator David Camacho executed the warrant at Valadez’s residence, performed a search incident to arrest, and found four balloons of heroin; Valadez was prosecuted for possession and later convicted and sentenced (life) as habitual.
Valadez moved to suppress, arguing the affidavit lacked probable cause to support the organized‑criminal‑activity arrest warrant because it did not allege facts showing he acted as a gang member in committing the aggravated assault.
The trial court denied suppression (entered findings that probable cause existed for various felony offenses and officers acted in good‑faith reliance). The Fourth Court of Appeals affirmed, concluding the affidavit provided a substantial basis for the magistrate’s probable‑cause determination.

Issue	Valadez’s Argument	State’s Argument	Held
Whether the affidavit supporting the arrest warrant established probable cause for engaging in organized criminal activity (underlying: aggravated assault).	Affidavit contains only post‑event conduct (threats, witness intimidation, gang label) and lacks facts showing Valadez participated in or conspired to commit the aggravated assault as a gang member.	The affidavit (unnamed witnesses, victim statement, reports, databases) supplied corroborated facts and reasonable inferences that Valadez conspired with Mexican Mafia members to commit the aggravated assault.	The court affirmed: under the totality of circumstances the magistrate had a substantial basis to find probable cause for the organized‑criminal‑activity warrant.

McFarland v. State, 928 S.W.2d 482 (Tex. Crim. App. 1996) (probable‑cause standard for affidavits supporting arrest warrants)
State v. McLain, 337 S.W.3d 268 (Tex. Crim. App. 2011) (review limited to four corners of affidavit for warrant analysis)
Flores v. State, 319 S.W.3d 697 (Tex. Crim. App. 2010) (totality‑of‑circumstances/substantial‑basis standard for magistrate’s probable‑cause determination)
Bonds v. State, 403 S.W.3d 867 (Tex. Crim. App. 2013) (standard of review for warrant‑based suppression motions)
Duarte v. State, 389 S.W.3d 349 (Tex. Crim. App. 2012) (magistrate may draw reasonable inferences; review realistic not hypertechnical)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (informant‑tip analysis and totality‑of‑circumstances approach to probable cause)