Crowley v. State

In Crowley v. State, 842 S.W.2d 701, 703 (Tex. App.--Houston 1st Dist. 1992, pet. ref'd), the defendant was involved in a traffic accident and fled the scene. 842 S.W.2d at 702. The occupants of the other car involved in the accident followed the defendant to a private residence and saw her pull into a detached garage and shut the door. See id. One of the occupants in the car stayed to watch the garage while the other went to call the police; the defendant did not leave the garage and was still there when the police arrived. See Crowley, 842 S.W.2d at 702-03. Because the witnesses had followed the defendant directly from the scene of the accident and because the defendant had been hiding in the garage while under surveillance until the police arrived, the Crowley court held the garage of the private residence was a suspicious place. Crowley, 842 S.W.2d at 703.