Yancy Leroy Britton, Appellant v. the State of Texas, Appellee

Summary

The Court held that the officer lacked probable cause to arrest appellant for public intoxication and therefore the pat‑down frisk was not justified; the heroin discovered was the fruit of an unlawful search and was excluded, resulting in reversal of the conviction and remand. The decision applied the Terry reasonable‑suspicion standard and the Chimel rule that a search incident to arrest requires a lawful arrest. Several dissenting judges argued that probable cause existed and the search was lawful, urging affirmation of the conviction.