Nathaniel Turner v. the State of Texas

Summary

The Court of Appeals for the Second District of Texas affirmed Nathaniel Turner's four plea-bargained convictions and concurrent five-year sentences. The court held that Turner forfeited his challenge to the initial detention and that the warrantless vehicle search was valid under the automobile and search-incident-to-arrest exceptions to the Fourth Amendment.

Holdings

1. Turner forfeited his complaint concerning the legality of the initial detention because he expressly abandoned that suppression ground during the trial-court hearing and argued only that the vehicle search lacked probable cause.
2. The warrantless search of Turner's vehicle was valid under the Fourth Amendment because officers had probable cause to believe the vehicle contained contraband or evidence of the narcotics offenses for which Turner was arrested.
3. A search incident to arrest may be valid when conducted immediately before formal arrest if officers had probable cause to arrest and reason to believe the vehicle contained evidence of the offense of arrest.

Questions Presented

1. Whether Turner preserved or forfeited his appellate complaint that police lacked reasonable suspicion to detain him.
2. Whether officers had probable cause to arrest Turner and search his readily mobile vehicle without a warrant under the Fourth Amendment.
3. Whether the vehicle search was valid as a search incident to arrest when conducted immediately before Turner's formal arrest.

Disposition

affirmed