Texas v. Copeland (Original)
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Deputy Jesse Garza of the Victoria County Sheriff's Office was observing a house known for illegal-narcotics activity. He saw a sports-utility vehicle ("SUV") approach the house and observed a passenger, appellee Shirley Copeland, got out, left the deputy's sight, and quickly returned to the SUV. After the SUV left the house, the deputy stopped the driver of the SUV for a traffic violation. Suspecting possible narcotics activity, the deputy asked the driver for consent to search the SUV. Danish agreed, but appellee refused. She claimed to be the owner of the SUV even though she was not listed as the owner on the vehicle registration. Appellee and the driver also informed the deputy that they were married under common law. Although appellee continued to refuse consent, the driver again consented, and the deputy searched the SUV. During his search, the deputy found two white pills, later identified as Tramadol, in the middle console. Appellee was arrested and charged with possession of a dangerous drug. Appellee filed a motion to suppress on two grounds: (1) the deputy's extended detention of her was not a permissible "Terry" stop; and (2) "Randolph" applieed to the search of vehicles just as it did to the search of residences. The trial court's order generally granted the motion, but its findings of fact and conclusions of law addressed only the second ground. The State appealed, arguing: (1) the trial court erred by finding that appellee and the driver were married under common law, (2) that appellee had standing to challenge the search; and (3) that the police officer did have valid consent through the driver. Because it held in appellee's favor, the court of appeals did not reach the first alternative ground in appellee's motion to suppress with respect to the length or scope of the detention. The sole ground on which the Supreme Court granted review in the State's petition for discretionary review challenged the court of appeals's application of "Randolph" to consensual searches of vehicles stopped on a public roadway. The Court agreed with the State that Randolph did not apply to vehicular searches and, therefore, reversed the judgment of the court of appeals. The case was remanded to appellate court so that it could determine whether the trial court's ruling on the motion to suppress should be upheld on the alternative ground asserted in appellee's motion.
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