Carol Ann Crowley v. State Texas

Appellant, Carol Ann Crowley, was convicted by the trial court of driving while intoxicated. Her punishment was assessed at 180 days confinement, probated, and a $250 fine. This Court reversed the judgment and remanded for a new trial, holding that the evidence was obtained as a result of an invalid warrantless arrest. Crowley v. State, No. 01-90-00362-CR (Tex. App.--Houston [1st Dist.], April 25, 1991). The court of criminal appeals granted the States petition for discretionary review and found that this Court failed to address one of the States reasons for upholding appellants conviction. The case is now before this Court on remand for consideration of the States argument that the warrantless arrest was valid under TEX. CODE CRIM. P. ANN. art. 14.03(a)(1) (Vernon Supp. 1992).