Victoria Morin v. State, 07-14-00101-CR

On Nov. 20, 2012, Victoria Morin was stopped by Lubbock County deputies for an inoperable high‑mounted center taillamp; officers smelled burnt marijuana on approach.
Officer Johnson asked for ID, had Morin exit the vehicle, and asked about the marijuana odor; Morin said the passenger had been smoking and admitted more marijuana was in her purse.
Johnson Mirandized Morin; a drug dog alerted to the driver’s side door and Morin’s purse; a subsequent search found ~15.1 grams of marijuana in the purse.
Morin moved to suppress, arguing the stop lacked reasonable suspicion (the taillamp violation is not a Texas offense), and that pre‑Miranda statements were custodial and coerced.
The trial court denied suppression, found the stop lawful under Tex. Transp. Code §547.3215 (incorporating federal lighting standards), concluded the detention grew into an investigative detention (not custodial interrogation), and found probable cause for the search.
Morin was convicted of possession (≤2 ounces); on appeal she argued (1) chapter 547 is unconstitutionally vague and (2) pre‑Miranda admissions were the product of custodial interrogation. The court affirmed.

Issue	Morin's Argument	State's Argument	Held
Validity of traffic stop (vagueness)	Chapter 547 is unconstitutionally vague as a whole; inoperable high‑mounted center taillamp is not a traffic offense	Stop was supported by reasonable suspicion under Tex. Transp. Code §547.3215 (federal standards incorporated)	Issue forfeited: Morin did not preserve constitutional vagueness claim at trial; stop otherwise supported by officer’s observation of taillamp defect
Pre‑Miranda statements (custodial interrogation)	Admissions about passenger and marijuana in purse were elicited by interrogation before Miranda and should be suppressed	Statements were the product of an investigative detention (not custodial); alternatively any error was harmless because later Mirandized admissions and dog alerts provided independent probable cause	Court accepted trial court’s finding of non‑custodial investigatory detention; even if error, admission harmless because cumulative of later Mirandized admission and independent probable cause

Guerra v. State, 432 S.W.3d 905 (Tex. Crim. App.) (discusses reasonable‑suspicion standard for investigative stops)
Abney v. State, 394 S.W.3d 542 (Tex. Crim. App.) (officer must have facts supporting inference that vehicle lacked required equipment)
Resendez v. State, 306 S.W.3d 308 (Tex. Crim. App.) (preservation rules: trial objections must comport with appellate complaints)
Swain v. State, 181 S.W.3d 359 (Tex. Crim. App.) (global or nonspecific trial objections generally fail to preserve appellate issues)
Lovill v. State, 319 S.W.3d 687 (Tex. Crim. App.) (complaint preserved only if trial judge could understand and correct the error)
Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App.) (deference to trial court’s factual findings on voluntariness and custody)
Clay v. State, 240 S.W.3d 895 (Tex. Crim. App.) (harmless‑error analysis for erroneously admitted statements)
Wilson v. State, 71 S.W.3d 346 (Tex. Crim. App.) (appellate point must comport with trial objection to be preserved)