Court of Criminal Appeals of Texas

John Crittenden, Appellant v. the State of Texas, Appellee

May 17, 19951995 Tex. Crim. App. LEXIS 57

Summary

The Court affirmed the Court of Appeals, holding that under Article I, § 9 of the Texas Constitution an objectively valid traffic stop is not unlawful even if the officer had an ulterior motive, thereby adopting a purely objective test for pretextual seizures. The majority reasoned that this approach aligns with its prior decision in Garcia and the weight of authority favoring the objective standard. A dissent argued that the objective test abandons the pretext doctrine and advocated a modified‑objective review, urging reversal and suppression of the evidence.