Robert Delgado, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals of Texas affirmed the conviction of Robert Delgado, holding that his warrantless arrest was lawful under Article 14.01(b) because the officer had probable cause, and that the subsequent inventory search of the automobile's trunk was valid either as an inventory or as a probable‑cause search. The majority relied on established Fourth Amendment jurisprudence and Texas statutes. Justice Clinton dissented, arguing that Article 14.01(b) requires the offense to be committed in the officer's presence and that the inventory issue was not before the court.