The State of Texas v. Jesus Sanchez

CourtCourt of Appeals of Texas
DecidedSeptember 10, 2025
Docket04-24-00435-CR
StatusPublished

This text of The State of Texas v. Jesus Sanchez (The State of Texas v. Jesus Sanchez) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The State of Texas v. Jesus Sanchez, (Tex. Ct. App. 2025).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-24-00435-CR

The STATE of Texas, Appellant

v.

Jesus SANCHEZ, Appellee

From the County Court at Law No 2, Webb County, Texas Trial Court No. 2020CRB000444L2 Honorable Leticia Martinez, Judge Presiding

Opinion by: Lori Massey Brissette, Justice

Sitting: Lori I. Valenzuela, Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: September 10, 2025

REVERSED AND REMANDED

The State appeals the trial court’s suppression of appellee Jesus Sanchez’s blood test results

after he was arrested for driving while intoxicated (DWI). The State argues the trial court erred by

suppressing appellee Jesus Sanchez’s blood test results because (1) the state trooper involved had

reasonable suspicion to conduct a traffic stop, (2) the state trooper did not prolong Sanchez’s

detention, (3) the state trooper had probable cause to arrest Sanchez for DWI, and (4) Sanchez 04-24-00435-CR

freely and voluntarily consented to the blood test. Based on the law and the record, we reverse and

remand for further proceedings consistent with this opinion.

BACKGROUND

State Trooper Carlos Martinez of the Texas Department of Public Safety was patrolling

Highway 359 when he noticed Sanchez’s car was on the road with a defective license plate lamp.

He stopped Sanchez’s vehicle, informed Sanchez of the reason, and proceeded to investigate

Sanchez’s traffic violation by checking the vehicle’s inspection sticker and VIN number. He

testified that while checking the VIN number, he smelled alcohol coming from the vehicle and

asked Sanchez if he had consumed any alcohol. Sanchez replied he did drink three beers, but he

did not indicate when he drank them. Trooper Martinez then began to investigate Sanchez for

DWI. See TEX. PENAL CODE § 49.04(a). After conducting the standard field sobriety tests, and

believing he failed some of them, Trooper Martinez arrested Sanchez for DWI. After the arrest,

Trooper Martinez repeatedly tested Sanchez’s breath, with his consent, yielding results of 0.00.

He then asked Sanchez, who was sitting handcuffed in the patrol unit, if he would be willing to

submit to a blood test. Sanchez agreed. The results showed Sanchez tested positive for cocaine.

On April 4, 2024, Sanchez filed his motion to suppress which sought to suppress the results

of the blood test as well as any statements made by him and any videos of him. During the May 7,

2024 hearing, the State called its only witness, Trooper Martinez. On June 13, 2024, the trial court

granted in part the motion to suppress, suppressing only the blood test results. This appeal

followed.

MOTION TO SUPPRESS

The State contends the trial court erred when it suppressed Sanchez’s blood test result.

Specifically, it argues the trial court erred because Trooper Martinez: (1) had reasonable suspicion

-2- 04-24-00435-CR

to conduct Sanchez’s traffic stop and did not subject Sanchez to a prolonged detention, (2) had

probable cause to arrest him for DWI, and (3) Sanchez voluntarily consented to the blood draw.

A. The Hearing and Video Evidence

During the motion to suppress hearing, Trooper Martinez testified that, on October 19,

2019 around 9:30 p.m., he began to follow Sanchez’s pickup truck because he noticed Sanchez’s

license plate light was out as Sanchez passed his vehicle. As he approached Sanchez’s vehicle in

his patrol unit, Trooper Martinez positioned his patrol unit in the left lane—with Sanchez’s vehicle

in the right lane—so that the patrol unit’s headlights would not illuminate the license plate of

Sanchez’s vehicle. This allowed Trooper Martinez to confirm the license plate lamp was not

illuminated by the vehicle’s license plate lights. He further testified that when he was

approximately twenty feet from the back of Sanchez’s vehicle, the license plate was still not clearly

legible as required by Texas Transportation Code § 547.322(f). He then initiated a traffic stop.

After both vehicles pulled over to the side of the road for the traffic stop, Trooper Martinez

approached Sanchez’s vehicle on the passenger side. As he approached the vehicle, he reconfirmed

one of the two license plate lamps was defective and not illuminated. 1 While he asked Sanchez for

identification, Trooper Martinez also indicated he would give Sanchez a warning for the traffic

violation. He testified that at that point he had no reason to suspect any other criminal activity.

When Sanchez responded he did not have identification, Trooper Martinez asked Sanchez to step

out of the vehicle so that he could identify him; Sanchez complied. Sanchez stood outside the

passenger side of the vehicle while the trooper then approached the driver’s side to check the

registration to determine if the information matched the VIN number and the license plate number.

1 He testified that once he had stopped Sanchez’s vehicle, he parked his patrol unit directly behind it, and the video showed the patrol unit’s headlights illuminating the back of Sanchez’s pickup including the license plates.

-3- 04-24-00435-CR

Trooper Martinez testified he initially smelled alcohol while he was at the passenger door.

But while he was walking back from the driver side where he was checking the VIN number, the

driver’s door window was down, and he smelled alcohol coming from inside the vehicle. He began

looking for an open container or spilled alcohol in the vehicle. He then asked Sanchez if he had

been drinking, and Sanchez responded he had consumed three twelve-ounce Bud Lights but did

not state when he had done so. The Trooper then told Sanchez he could smell alcohol coming from

his breath and from the vehicle and that he had confirmed the license plate number and the

“sticker” on the vehicle did not match the VIN number. Sanchez replied that it was not his vehicle.

Trooper Martinez then conducted a standard field sobriety test involving Sanchez’s eyes—

the horizontal gaze nystagmus—which he testified Sanchez failed. He then asked Sanchez to do

the walk and turn test, and Sanchez explained he could not do it, he was nervous, and “I’m not

gonna pass.” He then asked Sanchez to do the one leg stand test and then the hand pat test. Finally,

Trooper Martinez asked Sanchez to do the finger count test, and the trooper testified he saw

intoxication clues in the finger count test.

At the conclusion of the tests, and after a total of fourteen minutes, Trooper Martinez told

Sanchez that based on the fact that he smelled like alcohol and failed the field sobriety tests, he

was placing him under arrest for DWI. Sanchez fully cooperated and put his hands behind his back

to be handcuffed. Trooper Martinez handcuffed him, read him his Miranda rights, searched him,

and then placed him inside the front seat of the patrol unit.

Trooper Martinez then proceeded to pull up some records on his patrol unit terminal and

had Sanchez listen to additional statutory warnings via an automated recording, providing Sanchez

with a handout of the same to follow along. The recording provided that Sanchez would:

be asked to give a specimen of breath and/or blood and the specimen will be analyzed to determine the alcohol concentration or the presence of a controlled

-4- 04-24-00435-CR

substance, drugs, or other substances in your body.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Schneckloth v. Bustamonte
412 U.S. 218 (Supreme Court, 1973)
Ornelas v. United States
517 U.S. 690 (Supreme Court, 1996)
Amador v. State
275 S.W.3d 872 (Court of Criminal Appeals of Texas, 2009)
Lambeth v. State
221 S.W.3d 831 (Court of Appeals of Texas, 2007)
Kirsch v. State
306 S.W.3d 738 (Court of Criminal Appeals of Texas, 2010)
Harrison v. State
205 S.W.3d 549 (Court of Criminal Appeals of Texas, 2006)
Johnson v. State
68 S.W.3d 644 (Court of Criminal Appeals of Texas, 2002)
Finley v. State
809 S.W.2d 909 (Court of Appeals of Texas, 1991)
Derichsweiler v. State
348 S.W.3d 906 (Court of Criminal Appeals of Texas, 2011)
State v. Mosely
348 S.W.3d 435 (Court of Appeals of Texas, 2011)
Meekins v. State
340 S.W.3d 454 (Court of Criminal Appeals of Texas, 2011)
State v. Weaver
349 S.W.3d 521 (Court of Criminal Appeals of Texas, 2011)
State of Texas v. Ortiz, Octavio
382 S.W.3d 367 (Court of Criminal Appeals of Texas, 2012)
State of Texas v. Duran, Anthony
396 S.W.3d 563 (Court of Criminal Appeals of Texas, 2013)
State v. Villarreal, David
475 S.W.3d 784 (Court of Criminal Appeals of Texas, 2014)
Murray, Chad William
457 S.W.3d 446 (Court of Criminal Appeals of Texas, 2015)
Donna Jean Dill A/K/A Donna Zill v. State
355 S.W.3d 778 (Court of Appeals of Texas, 2011)
Larry Torres v. State
482 S.W.3d 629 (Court of Appeals of Texas, 2015)
State v. Evans
500 S.W.3d 528 (Court of Appeals of Texas, 2016)
Doremus v. State
530 S.W.3d 277 (Court of Appeals of Texas, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
The State of Texas v. Jesus Sanchez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-state-of-texas-v-jesus-sanchez-texapp-2025.