Lawrence Preston Miles, Appellant v. the State of Texas

Summary

The Court affirmed that a private tow‑truck driver may lawfully make a citizen's arrest for driving while intoxicated and that violations of traffic laws made in the course of that arrest do not trigger the Texas exclusionary statute, Article 38.23(a). Justice Price, in a concurring opinion, agreed with the judgment but rejected the majority's new rule equating private‑person conduct with that of police officers.