David Edwin Wiede, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals reversed the Third Court of Appeals and reinstated the trial court's judgment, holding that police had probable cause to search David Wiede's wrecked car after a bystander reported seeing him hide a clear plastic bag between the seat and console following the accident. It faulted the court of appeals for a prohibited piecemeal, 'divide-and-conquer' analysis and for failing to afford almost total deference to the trial judge's implicit historical-fact findings, emphasizing that probable cause turns on the facts known to officers at the time of the search. Viewing the accident, the furtive concealment before numerous officers, the bystander's contemporaneous report, and the officers' shared information and training as a totality, the Court concluded the search was supported by probable cause. The Court assumed without deciding that Wiede retained a reasonable expectation of privacy in the vehicle's contents, dismissing the State's first ground for review; Justices Johnson and Holcomb concurred without separate opinions.