In an opinion delivered by Justice Parker, the court held that the court of appeals made a "foundational mistake" by conflating independent grounds for seeking relief with independent grounds for supporting a judgment. The State had argued at the suppression hearing that the officer-citizen encounter was consensual until reasonable suspicion arose, and alternatively, that the officer was acting under a community-caretaking function.
The trial court granted the motion to suppress, finding the encounter was a seizure the officer parked behind the vehicle and that the community-caretaking justification dissipated before reasonable suspicion developed.
On appeal, the State raised only the consensual-encounter argument. The court of appeals concluded the State forfeited the issue because it did not challenge the trial court’s findings regarding the cessation of the community-caretaking function. The appellate court held that because the State failed to challenge every independent basis for upholding the trial court’s decision, it must affirm.
The Court of Criminal Appeals rejected this reasoning, stating that the two arguments were "independent reasons to deny the motion to suppress" rather than independent reasons to uphold it.
"The Calloway rule that the court of appeals indirectly relied upon does not hold to the contrary," the opinion read. "The point of that rule is that the trial court’s 'ruling' is upheld if it is 'correct on any theory of law applicable to the case and reasonably supported.' But if one of the State’s independent theories for denying relief is correct, then the trial court’s suppression ruling is not correct."
The court distinguished its prior decision in State v. Copeland, where the State failed to challenge one of two independent grounds for suppression raised by the defendant. In that case, the State was required to defeat both bases to prevail. Here, because the trial court suppressed the evidence, the State only needed to defeat one of its independent arguments to obtain reversal.
Appellee Martin Young conceded in his briefing that the court of appeals made a "category error," agreeing that the State’s claims were "independent grounds for refuting" the ruling, not supporting it.
Despite the concession, the court declined to address the merits of the consensual-encounter claim itself, rejecting arguments from a concurring and dissenting opinion that judicial economy warranted first-instance review. The majority emphasized that the court of appeals is tasked with deciding issues of error instance and that the case must be remanded for that court to address the State’s point of error.
The opinion was joined by Justices Richardson, Newell, Keel, and Finley. Justice Yeary joined except for part II B. Justice McClure concurred. Chief Justice Schenck filed a concurring and dissenting opinion joined by Justice Walker.