Court of Criminal Appeals of Texas
Jeremy Wayne Baldwin, Appellant v. the State of Texas
March 11, 20092009 Tex. Crim. App. LEXIS 318
Summary
The Court held that Deputy Smith exceeded his authority by handcuffing Baldwin and reaching into his pocket to retrieve his wallet without probable cause, rendering the search unlawful and reversing the judgments of the lower courts. The opinion further concluded that handcuffing a suspect without reasonable suspicion converts a detention into a de facto arrest, requiring suppression of the discovered contraband, and remanded the case for further proceedings. Separate concurring opinions debated whether the encounter constituted an arrest or merely an unlawful detention.