THE STATE OF FLORIDA, APPELLANT,
v.
RANDY FERGUSON, APPELLEE
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Florida appealed a trial court's suppression of defendant Randy Ferguson's statements to police. The trial court had suppressed the statements because they were allegedly derived from confessions obtained illegally from co-defendants in violation of their Fourth Amendment rights. The appellate court reversed, holding that Ferguson had no standing to challenge Fourth Amendment violations suffered by third parties.
A defendant has no standing to challenge Fourth Amendment violations suffered by third parties and cannot use such violations as a basis for suppressing his own statements. Because the police did not violate Ferguson's own Fourth Amendment rights, the suppression order was erroneous.
[1] A defendant may only suppress evidence obtained in violation of their own Fourth Amendment rights, not those of a third party.
[2] A defendant lacks standing to challenge the legality of a search or seizure that violates the Fourth Amendment rights of a co-defendant or coconspirator.
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Join FLexlaw to unlock all legal intelligence“suppression of the product of a Fourth Amendment violation can be successfully urged only by those whose rights were violated by the search itself, not by those who are aggrieved solely by the introduction of damaging evidence. Coconspirators and co-defendants have been accorded no special standing.”
Establishes the core standing doctrine: only those whose own constitutional rights were violated may seek suppression; co-defendants cannot challenge violations of each other's rights.
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Join FLexlaw to unlock all legal intelligencePolice obtained confessions from co-defendants Sands and Thomas. The Sands confession resulted from execution of a fatally defective search warrant, a…
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PER CURIAM.
We have for review an order of the trial court suppressing certain statements made by the defendant Randy Ferguson to the police. The sole basis for suppressing the statements was the trial court’s determination that: (1) the statements constituted “the direct product of a confrontation between the defendant and the written confessions obtained by co-defendants Sands and Thomas,” and (2) “the statements of the co-defendants were illegally obtained” in that (a) “the statement of Sands was the fruit of the execution of a fatally defective search warrant,” and (b) “[t]he statement of Thomas was the fruit of an arrest in violation of Payton v. New York, 445 U.S. 573, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980), and the principles enunciated therein.” In short, the trial court below suppressed the defendant’s statements because they constituted the fruit of confessions obtained from third parties by the police in violation of the said third parties’ Fourth Amendment rights.
We are compelled to reverse the order under review, because, concededly, the police at no time violated the Fourth Amendment rights of the defendant — only, allegedly, the Fourth Amendment rights of third parties. The law is well-settled that “ ‘suppression of the product of a Fourth Amendment violation can be successfully urged only by those whose rights were violated by the search itself, not by those who are aggrieved solely by the introduction of damaging evidence. Coconspirators and co-defendants have been accorded no special standing.’ ” Brown v. State, 245 So. 2d 68, 74 (Fla.1971), quoting with approval from Alderman v. United States, 394 U.S. 165, 171-72, 89 S.Ct. 961, 965, 22 L.Ed.2d 176 (1969); see also United States v. Salvucci, 448 U.S. 83, 87 n.4, 100 S.Ct. 2547, 2551 n.4, 65 L.Ed.2d 619 (1980); United States v. Payner, 447 U.S. 727, 731, 100 S.Ct. 2439, 2443, 65 L.Ed.2d 468 (1980); Rakas v. Illinois, 439 U.S. 128, 99 S.Ct. 421, 58 L.Ed.2d 387 (1978); Morales v. State, 407 So. 2d 321 (Fla. 3d DCA 1981); St. John v. State, 400 So. 2d 779, 780 (Fla. 1st DCA 1981).
As such, the defendant Ferguson herein had no standing to complain that the police allegedly violated the Fourth Amendment rights of Sands and Thomas; and, as the police, concededly, did not violate the defendant’s Fourth Amendment rights, it follows that the trial court committed reversible error in suppressing the said defendant’s statements to the police based on Fourth Amendment grounds. The order under review is, accordingly, reversed and the cause is remanded to the trial court for further proceedings.
Reversed and remanded.
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State v. Eber, 502 So. 2d 32 (Fla. 3d DCA 1987)…lain of infringements on the constitutional rights of others. Alderman v. United States, 394 U.S. 165, 89 S.Ct. 961, 22 L.Ed.2d 176 (1969); Sarno v. State, 424 So. 2d 829 (Fla. 3d DCA 1982), rev. denied, 434 So. 2d 888 (Fla.1983); State v. Ferguson, 411 So. 2d 963 (Fla. 3d DCA 1982). Although the trial court apparently — and correctly — concluded that San Roman was neither a party to any unlawfully intercepted wire or oral communication nor a person against whom such interception was directed, it neverthele…
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State v. Torres, 412 So. 2d 941 (Fla. 3d DCA 1982)…olved in the order below— Torres’ fingerprint standards and those found at the scene of the offense, see State v. Tillman, 402 So. 2d 19 (Fla. 3rd DCA 1981); a firearm discarded by his co-defendant as they were being stopped, see, State v. Ferguson, 411 So. 2d 963 (Fla. 3rd DCA 1982); and the victim’s incourt identification, see United States v. Crews, 445 U.S. 463, 100 S.Ct. 1244, 63 L.Ed.2d 537 (1980); State v. Tillman, supra; State v. Maier, 378 So. 2d 1288 (Fla. 3rd DCA 1979) — was the product of or legal…
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State v. Williams, 424 So. 2d 212 (Fla. 2d DCA 1983)…22, 99 S.Ct. 1035, 59 L.Ed.2d 83 (1978). The officers did not violate the appellee’s fourth amendment rights. Therefore, appellee has no standing to complain that the officers violated the fourth amendment rights of third parties. State v. Ferguson, 411 So. 2d 963 (Fla. 3d DCA 1982). “ ‘ * * * suppression of the product of a Fourth Amendment violation can be successfully urged only by those whose rights were violated by the search itself, not by those who are aggrieved solely by the introduction of damaging e…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Rakas v. Illinois, 439 U.S. 128 (U.S. 1978)
- Payton v. New York, 445 U.S. 573 (U.S. 1980)
- Alderman v. United States, 394 U.S. 165 (U.S. 1969)
- United States v. Salvucci, 448 U.S. 83 (U.S. 1980)
- United States v. Payner, 447 U.S. 727 (U.S. 1980)
- Brown v. State, 245 So. 2d 68 (Fla. 1971)
- Zeinida Morales v. State, 407 So. 2d 321 (Fla. 3d DCA 1981)
- ST. John v. State, 400 So. 2d 779 (Fla. 1st DCA 1981)