Garcia v. State (1992)

In Garcia v. State, 827 S.W.2d 937 (Tex. Crim. App. 1992) the Court explained that the phrase "pretext arrest" was used to refer to an "objectively" valid stop for an allegedly improper reason. Id. at 939-40. In line with Supreme Court and federal authority, the Court abandoned the "pretext arrest" concept in favor of a purely objective analysis. The Court held that, "as long as an actual violation occurs, law enforcement officials are free to enforce the laws and detain a person for that violation . . . regardless of the officer's subjective reasons for the detention. Id. at 944.