TX14: Driving slow on low tires in the middle of nowhere justified community caretaking stop

Defendant’s stop was objectively reasonable under the community caretaking function. He was driving 10 in 25 mph zone with seriously deflated tires causing the car to wobble on the highway, and it was in the middle of nowhere. Lollie v. State, 2015 Tex. App. LEXIS 4078 (Tex. App. – Houston (14th Dist.) April 23, 2015).

Defendant, an invitee, did not have standing to challenge police entry into a lot next to stables. He had no past history there, many people had access, and he had no right to control access himself. It was also an area essentially exposed to the public. United States v. Silva-Rentas, 2015 U.S. Dist. LEXIS 53545 (D.P.R. April 21, 2015),* adopted 2015 U.S. Dist. LEXIS 72620 (D.P.R. June 3, 2015.*

The Tenth Circuit has never held that flight from a vehicle that crashed during a police chase was abandonment. Every other circuit to consider the question has said this is abandonment, and that’s what the court holds. United States v. Russian, 2015 U.S. Dist. LEXIS 53350 (D.Kan. April 23, 2015).*