Reported / Citable
Background
Arturo Montes, Jr. exited Interstate 40 and approached an intersection of State Highway 207 and the I-40 frontage road. Trooper Alexandrea Moroles saw Montes stop on top of a partially faded white stop line before turning left. She also believed he activated his turn signal fewer than 100 feet before the turn.
Moroles stopped Montes and issued only a warning for failing to stop behind the line. Montes then consented to a vehicle search, which produced suspected narcotics. A federal indictment charged him with fentanyl-distribution offenses. Montes moved to suppress the evidence, challenging the legality of the initial stop but not the consent search itself.
The Court’s Holding
The court denied the suppression motion. It held that Moroles had reasonable suspicion to stop Montes based on her observation that he stopped on top of a faded-but-visible stop line. Even if the line was not ultimately “clearly marked” under Texas law, Moroles reasonably believed that it was and that Montes had violated Texas Transportation Code Section 544.010(c).
The court also found an independent basis for the stop: Moroles reasonably believed Montes had failed to signal continuously for the last 100 feet before turning. Later measurements indicated Montes began signaling about 122.5 feet from the intersection, but the court concluded that Moroles’s roughly 22.5-foot mistake was reasonable given the curve in the road, the moving vehicle, and the simultaneous brake lights. Either apparent violation justified the stop under the Fourth Amendment.
Key Takeaways
- A traffic stop may rest on reasonable suspicion, including a reasonable mistake of fact, rather than proof that a traffic violation actually occurred.
- An officer reasonably could treat a partially faded stop line as enforceable where the officer observed it, knew the intersection, and saw the vehicle stop on or beyond it.
- A close distance estimate about turn-signal timing can support reasonable suspicion when roadway conditions make precise observation difficult.
Why It Matters
The decision applies the Fourth Amendment’s reasonableness standard to common traffic-stop observations. It underscores that suppression does not follow merely because later evidence shows an officer’s on-scene assessment was inaccurate; the dispositive question is whether the mistake was reasonable when the stop occurred.
For criminal practitioners, the opinion also illustrates the importance of developing the officer’s vantage point, road conditions, prior knowledge, and contemporaneous observations at a suppression hearing.