State v. Martinez
No. 05-19-01395-CR (Tex. App. 2021)
Holding
Evidence obtained during a traffic stop was properly suppressed where the officer lacked reasonable suspicion to extend the stop beyond its original purpose and conducted a search without valid consent or probable cause.
What This Case Is About
State v. Martinez addressed whether officers had probable cause to arrest Roger Anthony Martinez for public intoxication without a warrant. The Texas Court of Criminal Appeals reversed the court of appeals, finding that probable cause existed and remanding the case for further proceedings.
The Facts
Roger Anthony Martinez was arrested for public intoxication without a warrant. He filed a motion to suppress challenging the legality of his arrest. The trial court granted the motion, and the court of appeals affirmed. The State sought discretionary review in the Texas Court of Criminal Appeals.
Officers Guerrero and Ramirez testified at the suppression hearing that they observed facts constituting the offense of public intoxication: that Martinez was in a public place, that he was intoxicated, and that he posed a danger to himself or others.
What the Court Decided
The Texas Court of Criminal Appeals reversed the court of appeals, finding that probable cause existed to arrest Martinez for public intoxication. The court applied the burden-shifting framework from Russell v. State: when a defendant establishes that a search or seizure occurred without a warrant, the burden shifts to the State to prove the reasonableness of the search or seizure. Here, the State met its burden by showing that officers observed facts constituting the offense of public intoxication committed in their presence.
Why This Case Matters for Your § 1983 Case
Warrantless arrests require probable cause. When officers arrest without a warrant, the burden is on the State to demonstrate that the arrest fell within an exception to the warrant requirement — such as an offense committed in the officer’s presence.
The burden-shifting framework matters. In suppression hearings, the defendant bears the initial burden of showing the seizure was warrantless, then the burden shifts to the State to justify the arrest.
Key Takeaway
Officers may arrest without a warrant for offenses committed in their presence, including public intoxication. The State bears the burden of proving that the warrantless arrest was supported by probable cause based on the officers’ observations at the time.