Texas Defendant Unsuccessfully Appeals Lower Court’s Ruling on Motion to Suppress, Due in Part to Additional Offense Committed

In a November 2023 case before an appeals court in Texas, the defendant asked for a review of the trial court’s decision to deny his motion to suppress evidence. Reviewing the defendant’s appeal, the higher court ultimately disagreed with his argument and affirmed the original verdict. The court’s opinion highlights the difficulty of suppressing incriminating evidence when a defendant commits multiple offenses in a row, serving as a reminder for Texans of just how difficult it can be to successfully suppress evidence in criminal cases.

Facts of the Case

According to the opinion, officers on patrol one evening used an automated license plate reader to discover that a nearby vehicle’s owner was wanted on multiple outstanding arrest warrants. Additionally, the officers noticed that the vehicle did not match the one for which the vehicle’s tags had been issued.

The officers put on their lights and attempted to conduct a traffic stop. The defendant stopped at first, but then he proceeded to flee the scene. What ensued was a high-speed chase that lasted approximately one hour. Eventually, officers used spike strips to stop the defendant in his car. The officers then arrested the defendant for avoiding arrest.

The Decision

The defendant filed a motion to suppress incriminating evidence, arguing that the officer had no right to initiate a traffic stop based solely on the license plate reader’s information. The trial court denied the motion, and the defendant’s case went to trial. He was found guilty of evading arrest, and the trial court sentenced him accordingly. The defendant promptly appealed the lower court’s denial of his motion to suppress.

On appeal, the higher court looked at whether the officers had the right to initiate a traffic stop. Ultimately, said the court, it was relevant that the defendant committed a new offense (i.e., evading arrest) after the officer initiated the traffic stop. Even if the officer unreasonably initiated the traffic stop, the fact that the defendant then fled allowed the officer to pursue him through the high-speed chase.

Because the defendant clearly fled the scene, going over one hundred miles per hour in a 35-mile-per-hour zone, the officer’s chase was justified. The court denied the defendant’s appeal, deciding that the trial court rightfully denied the motion to suppress. Given the defendant’s decision to flee from the scene, which constituted a separate offense, the trial court’s decision was appropriate and would remain in place.

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