Bilyeu v. State

In Bilyeu v. State, 136 S.W.3d 691 (Tex. App.--Texarkana 2004, no pet.), two police officers were taking a break in the parking lot of a convenience store at approximately 2:00 a.m. when they were approached by an unidentified citizen who reported that he had seen a woman asleep at the wheel of a gold Mercedes-Benz automobile while stopped at a nearby intersection while the traffic light was green. The citizen then identified the vehicle as it slowly passed by the officers' location at ten miles per hour in a thirty-five-mile-per-hour zone. The officers stopped the vehicle and determined the driver was intoxicated. The court of appeals held the information provided by the unnamed citizen was akin to information from an anonymous tip. Id. at 695 n.3.