Castro v. State (2007)
In Castro v. State, 227 S.W.3d 737 (Tex. Crim. App. 2007), Castro was a passenger in a vehicle that was stopped for failure to signal a lane change, in violation of section 545.104. See Castro, 227 S.W.3d at 739.
Officers found a bag of narcotics and arrested Castro. Id.
Deputy Bailey, who had been investigating Castro's association with a drug lab, was called to the scene. Id. At a suppression hearing, Bailey testified that the vehicle was stopped for "failure to signal a lane change." Id.
Bailey did not witness the driver's actions. See id.
The trial court denied the motion to suppress, but the appellate court reversed. Id. at 740.
"It was within the trial court's discretion to believe or disbelieve the testimony and use it as a basis for the ruling on the motion to suppress." Id. at 743.
"In the case of offenses requiring only an objective determination of whether the offense was indeed committed, the court does not need to know the subjective details of the stop from the officer's standpoint in order to find that the stop was reasonable." Id.
The Court further explained when a conclusory statement will suffice for establishing reasonable suspicion.
When reasonable suspicion is based on an objective observation or fact such as whether a defendant used his turn signal, a conclusory statement may suffice for determining reasonable suspicion. See id.
In dicta, the court stated that "being intoxicated" can be an example of a subjective determination that must be accompanied by specific and articulable facts to establish reasonable suspicion. See id.
The Court of Criminal Appeals found that the amount of specific and subjective detail that an officer must give to demonstrate that a traffic stop is reasonable depends on the nature of the offense. See id. at 742.
When the determination of whether an offense has been committed requires an officer to make a subjective determination, then the officer must provide a detailed account of his observations to support that determination. See id.
The offense involved in Castro was one requiring the officer to make an objective determination. See Castro, 227 S.W.3d at 742.
There, the officer testified that the defendant's vehicle was stopped because the defendant failed to signal a lane change, which is a traffic offense. Id. at 739-40.
The Castro Court explained that "in cases involving offenses such as failure to signal a lane change, a court can determine whether an officer's determination that a driver committed a traffic violation was objectively reasonable without being presented with a detailed account of the officer's observations." Id. at 742.
In short, it explained that "the determination of whether a driver signaled a lane change is a simple one." Id.