Love v. State
The appellant pleaded guilty to possession with intent to deliver a controlled substance and had his probation revoked due to an offense in cause no. 392,502. The appellant argued that the controlled substance was obtained through an illegal warrantless arrest and search conducted by Pasadena city police outside their jurisdictional limits in Houston. The court examined common-law rules, statutory interpretations (Tex.Rev.Civ.Stat.Ann. arts. 998 and 999), and Code of Criminal Procedure articles (e.g., art. 14.01(b)) concerning the territorial authority of city police officers. It concluded that city police do not possess general countywide or statewide warrantless arrest powers unless specific statutory exceptions (like hot pursuit) apply, which were not present in this case. Consequently, the court held that the Pasadena officers lacked the authority for the arrest and search, reversing the trial court's judgment and remanding the cause for a new trial.