The State of Texas v. Candelario Garcia-Cantu, Appellee

Summary

The Court of Criminal Appeals held that, under Florida v. Bostick's totality-of-the-circumstances test, Officer Okland's conduct — activating a spotlight before stopping, parking about ten feet behind and to the left of Garcia-Cantu's legally parked truck so as to box it in on a narrow dead-end street at 4:00 a.m., approaching with a long flashlight at shoulder level, and issuing commanding questions and orders — communicated to a reasonable person that he was not free to leave, constituting a Fourth Amendment detention requiring reasonable suspicion. The trial court therefore did not err in granting the motion to suppress, and the court of appeals erred by treating the spotlight as the dispositive single fact. The court reversed the court of appeals' judgment, upheld the suppression ruling, and remanded. Judge Keasler and Presiding Judge Keller each filed dissenting opinions (joined by the other and by Judge Hervey) contending the interaction was a consensual encounter because Garcia-Cantu's restricted egress stemmed from his own choice to park on a dead-end street and he never expressed unwillingness to talk.