Court of Criminal Appeals of Texas

Wilton Larron Mahaffey, Appellant v. the State of Texas

June 30, 20102010 Tex. Crim. App. LEXIS 795

Summary

The Court held that a merge is not a "turn" under Texas Transportation Code §545.104(a) and therefore the signal requirement does not apply to a merge; it reversed the Court of Appeals and remanded for a determination whether the merge was a lane change requiring a signal. The dissent argued the majority overstates the holding and criticized reliance on administrative handbooks and prior case law.