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dispelled that newly-formed suspicion. Therefore, suspicion, it is slight unless the characteristic is
we must decide whether, and when, Woody ‘so unique in the area as to inherently raise
developed the reasonable suspicion necessary to suspicions.’” In this case, the district court
prolong the detention. In doing so, “[w]e must pay focused on that language, finding that the trailer’s
heed to the Supreme Court’s admonition not to “abnormalities” were not so unique because
treat each factor in isolation, but rather to give due “Texas law allows for an infinite number of
regard to the totality of the circumstances.” And trailers [with] an infinite number of
“in drawing inferences . . . , we must give due modifications,” and thus the combination of
weight to the inferences drawn by both the trial modifications alleged in this case were not
court and law enforcement officers.” inherently suspicious. The district court’s reliance
Faced with this question, the district court on Madrigal is misplaced. In Madrigal, the officer
concluded that Woody did not develop the stated that driving “an older and recently
suspicion necessary to extend the traffic stop registered truck” created suspicion because
beyond eleven minutes. The district court “many drug couriers use such vehicles.” That is
identified two possible bases for Woody’s to say, the vehicle was suspicious only because it
suspicion—Villafranco-Elizondo’s demeanor and fit into a particular profile. And, as we noted, it
modifications to the trailer—and held that neither was not particularly suspicious because such a
supported reasonable suspicion. We disagree. truck is also “a mode of transport for millions of
… low-income Americans.” The situation here is
qualitatively different. The modifications alleged
But the district court overlooked other aspects of are not features common to transport for millions
the encounter relevant to reasonable suspicion. of Americans, nor are they “mere
Regardless of his demeanor, Villafranco- customization[s] of the vehicle that could also
Elizondo’s answers to some of Woody’s questions support a conclusion of innocent travel.” The
were suspicious: he stated that he was planning at officers testified that the modifications were
most an overnight stay, but had packed a large consistent with a hidden compartment, and we
suitcase; he could not provide an address where he have repeatedly held that such evidence can lead
planned to pick up the equipment he had to reasonable suspicion or even probable cause.25
purchased; and he claimed to have purchased a After all, “[i]t is hard to conceive of a legitimate
concrete crawler for only 12.5% of its usual going use for a large hidden storage compartment in any
rate, a deal that seemed “too good to be true.” part of a vehicle.”

The district court did consider the modifications to When evaluating the likelihood that a
the trailer, but ultimately concluded that they were modification indicates a hidden compartment,
insufficient to create reasonable suspicion of “[c]ourts must allow law enforcement officers to
criminal activity. The district court relied on draw on their own experience and specialized
United States v. Madrigal, an unpublished opinion training to make inferences from and deductions
of this court that found no reasonable suspicion to about the cumulative information available to
extend a traffic stop based on: (1) the defendant’s them that might well elude an untrained person.”
travel itinerary; (2) “the fact that [the defendant] Woody had significant experience in drug
drove an older and recently registered truck”; and interdiction: he worked in the WBRSO criminal
(3) the defendant’s arrest record from fourteen interdiction unit for five years; performed
years prior.20 On the second factor, Madrigal held hundreds of traffic stops; and received training in
that “[a]lthough a vehicle feature may create detecting hidden compartments and vehicle

24 www.texaspoliceassociation.com • 866-997-8282 Texas Police Journal