“There is a well-known drug house in Houston where law enforcement has been making drug busts for more than thirty years. Appellant approached that drug house when police were surveilling it as part of an ongoing narcotics investigation. An undercover officer saw appellant exit his vehicle, enter the drug house on foot, and return after a few minutes. Appellant opened the hood of his vehicle for a brief mechanical inspection, and then he drove away. [¶] The undercover officer never witnessed appellant engage in a hand-to-hand transaction, but the officer suspected that appellant had completed a drug deal of some kind based on his presence at the drug house and on the short duration of his visit. The undercover officer radioed a marked patrol unit, which had been waiting nearby, and asked that unit to develop probable cause to stop appellant for a traffic violation.” Reasonable suspicion clearly developed on the totality. One of the officers turned off his body camera. He may have violated protocol, but not the Fourth Amendment. Medina v. State, 2018 Tex. App. LEXIS 10440 (Tex. App. – Houston (14th Dist.) Dec. 18, 2018).

Under the totality of circumstances, the officer lacked both probable cause and reasonable suspicion for defendant’s stop. United States v. Muse, 2018 U.S. Dist. LEXIS 209817 (E.D. La. Dec. 12, 2018)*:
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