Driving offenses can be indicators of drug trafficking and avoidance. “Therefore, based on the information he received from Captain Garrett related to appellant’s involvement in possible narcotics trafficking, combined with his observations of appellant driving on the shoulder, we conclude that Deputy Mace possessed specific, articulable facts that appellant was engaged in illegal drug activities, even if his testimony did not definitely prove that a violation of the Transportation Code occurred.” Enns v. State, 2020 Tex. App. LEXIS 8152 (Tex. App. – Houston (1st Dist.) Oct. 15, 2020).
Defendant’s unconditional guilty plea waived his Fourth Amendment challenges. United States v. Seabrooks, 2020 U.S. App. LEXIS 32574 (4th Cir. Oct. 15, 2020).*