Williams, Cristan Drayce, PD-1316-15

At ~3:00 a.m. in the Northgate entertainment/bar district parking garage, Sgt. Jason Summers observed Cristan Williams sitting in his vehicle and then driving "three laps" around the second level of the garage.
The garage was open and not fully cleared; patrons were still leaving after bars closed an hour earlier. Summers initially "didn't think too much of" Williams, became suspicious only after the laps, and stopped/detained him.
Williams was arrested for DWI and possession of marijuana; he later pled guilty to possession after the trial court denied his motion to suppress.
On appeal the Waco Court of Appeals affirmed the denial of the motion to suppress, reasoning that (under the totality of circumstances) driving laps in a nearly empty garage at that hour was unusual and reasonably related to DWI.
Williams petitioned the Court of Criminal Appeals, arguing the appellate court ignored precedent requiring an objective, articulated link between the observed conduct and criminal activity, and that the court improperly deferred to officer/trial-court conclusions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the investigatory stop was supported by reasonable suspicion	Williams: driving "three laps" in an open parking garage was innocent, not "sufficiently distinguishable" from lawful conduct and therefore did not supply reasonable suspicion for DWI	State: the totality of circumstances (nearly empty garage at 3 a.m., bars recently closed, laps around one level) made the conduct unusual and reasonably suggested DWI	Waco Ct. App.: affirmed denial of suppression — reasonable suspicion existed under the totality of circumstances
Proper standard of review / deference to trial court and officer testimony	Williams: appellate court erred by rubber‑stamping trial court/officer conclusions and failing to independently assess whether objective facts linked conduct to crime; officer training/experience were not articulated to bridge the gap	State: trial court credibility findings entitled to deference; appellate review gives weight to historical fact findings and evaluates reasonable suspicion under the totality of the circumstances	Waco Ct. App.: applied deferential view to trial court fact findings and concluded—on review—that reasonable suspicion existed

Wade v. State, 422 S.W.3d 661 (Tex. Crim. App. 2013) (courts must independently assess whether historical facts give rise to reasonable suspicion)
Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (reasonable‑suspicion framework: unusual activity, link to the individual, indication activity is related to crime)
White v. State, 574 S.W.2d 546 (Tex. Crim. App. 1978) (driving around a parking lot without apparent purpose provided no reason for suspicion)
Foster v. State, 326 S.W.3d 609 (Tex. Crim. App. 2010) (particular unsafe/erratic driving correlated to DWI may justify investigatory stop)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (officer inferences must be grounded in specific facts and permissible experience)
United States v. Cortez, 449 U.S. 411 (U.S. 1981) (Fourth Amendment requires specificity linking officer inferences to objective facts)
Navarette v. California, 572 U.S. 393 (U.S. 2014) (experience can inform reasonable suspicion for certain erratic driving behaviors)