Texas v. Sanchez (original by presiding judge keller)Annotate this Case
During a traffic stop, Appellee Reinaldo Sanchez was arrested for outstanding warrants. During that arrest, the officer searched Appellee’s person and discovered illegal drugs. The officer then searched Appellee’s Jeep and discovered more illegal drugs. The courts below held that the search of the Jeep was not a valid search incident to arrest because there was no reason to believe that the Jeep contained evidence relating to the outstanding warrants for which Appellee had been arrested. The court of appeals further held that the discovery of the illegal drugs on Appellee’s person could not supply a new basis for arrest, for the purpose of conducting a search incident to arrest, that would justify the search of the Jeep. The Court of Criminal Appeals disagreed and held that discovery of drugs on a suspect’s person, after an arrest on traffic warrants but before the search of the suspect’s vehicle, can supply a new basis for arrest that would justify search of the vehicle as a search incident to arrest.