In Mitchell v. State, 756 S.W.2d 71 (Tex. App.--Texarkana 1988, no pet.), police officers went to Mitchell's house where a stolen truck was reportedly parked. Mitchell, 756 S.W.2d at 72. Finding the truck in the front yard, the police used a loudspeaker to command the occupants to come out. Id. Mitchell and two others emerged. Id. at 72-73. One of the officers spoke briefly to Mitchell and then arrested him, but the other men were not arrested. Id. at 73. The court of appeals concluded that the presence of a stolen vehicle in the front yard "can reasonably be considered to qualify the yard and house as a 'suspicious place.'" Id. at 74. "However, there is no evidence in the record indicating that, of the three people in the house, Mitchell was the person the officers had probable cause to believe had stolen the vehicle. The record shows only that, after Mitchell and the two others exited the house, Sergeant Bless spoke with Mitchell briefly in Deputy Kuhn's presence and then arrested him. Bless did not testify at the suppression hearing, and there is nothing to show what, if anything, Mitchell said to him or what else may have supported Bless' decision to arrest Mitchell rather than one or both of the other occupants of the house." Id. The court held that the State failed to show that the warrantless arrest was authorized under Article 14.03(a)(1). Id.