Court of Criminal Appeals of Texas

Anthony Cordell Williams, Appellant v. the State of Texas, Appellee

September 17, 19861986 Tex. Crim. App. LEXIS 799

Summary

The Court affirmed the lower appellate court’s denial of the motion to suppress, holding that Officer Gildehaus had probable cause to arrest Williams for a parking violation and that the subsequent search of the vehicle was a valid search incident to that lawful custodial arrest. The decision relied on the principle that an officer’s subjective motive does not invalidate a search if the arrest is objectively justified, and it rejected the dissenters’ arguments that the officer’s purpose was a narcotics investigation and that no custodial arrest occurred. The dissenting opinions argued that the majority decided an issue not raised on appeal and that a warrantless arrest for a minor parking violation cannot justify a full vehicle search.