Lara v. State

In Lara v. State, 469 S.W.2d 177, 179 (Tex. Crim. App. 1971), the defendant was convicted of possession of a controlled substance and sentenced to life in prison. Id. at 178. At trial, the officers testified that they observed the defendant running from a known drug house. Ibid. They further testified that they apprehended the defendant and performed an initial search, and upon apprehending the remaining individuals, they read the defendant his rights. Ibid. They then performed a second search of the defendant and found a capsule of heroin. Ibid. On appeal, this Court affirmed the conviction, holding that there was no reversible error where, under all the circumstances observed by the officers and the facts known by them, they had probable cause and the defendant's arrest was authorized under the Code of Criminal Procedure Article 14.03(a)(1). Id. at 179. This test has been repeated on many occasions.