STATE OF FLORIDA, APPELLANT,
v.
BECKY ANN CRAWFORD, APPELLEE
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Florida appeals the suppression of methamphetamine and drug paraphernalia found in Crawford's billfold during a search incident to arrest at a residence where a search warrant was being executed. The court reverses the suppression order, holding that once officers discovered marijuana during a lawful pat-down search, they had probable cause to arrest Crawford and could search her person, purse, and billfold incident to that arrest.
The court held that the trial court erred in suppressing the items found in the billfold. Once deputies discovered the marijuana during the pat-down search, they had probable cause to arrest Crawford, and incident to that arrest they could search her person, purse, and billfold.
[1] A search of a person's purse and its contents, including a billfold, is permissible incident to a lawful arrest of that person.
[2] Discovery of contraband during a lawful pat-down search can establish probable cause for an arrest.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“When the deputies discovered the marijuana, they had probable cause to arrest Crawford. Once they had probable cause to arrest her, they could search her person and her purse incident to that arrest.”
The court's core holding establishing that the billfold search was lawful as incident to arrest.
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Join FLexlaw to unlock all legal intelligenceSheriff's deputies executed a search warrant at a residence. Crawford was visiting the house at the time. During a pat-down search for weapons, office…
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PER CURIAM.
The state appeals an order suppressing drugs and drug paraphernalia that law enforcement officers found inside Becky Crawford’s billfold. Crawford happened to be visiting a friend’s house when sheriff’s deputies executed a search warrant for the premises. The deputies patted her down for weapons, and when they pulled a hard object from her pocket a bag of marijuana came out with it. The deputies then searched her purse and the billfold inside it, finding crystal methamphetamine and drug paraphernalia inside the billfold. They arrested her, and the state charged her with possessing marijuana, crystal methamphetamine, and drug paraphernalia. Claiming that the search was illegal, Crawford moved to suppress these items. The trial court found that the marijuana was lawfully found during the pat-down search, but that the search of Crawford’s billfold was illegal. It therefore denied the motion as to the marijuana but granted it as to the crystal methamphetine and drug paraphernalia. The state appealed the order of suppression.
We conclude that the trial court erred in suppressing the items in the billfold. When the deputies discovered the marijuana, they had probable cause to arrest Crawford. . Once they had probable cause to arrest her, they could search her person and her purse incident to that arrest. See State v. Boulia, 522 So. 2d 528 (Fla. 2d DCA 1988). The billfold inside the purse was within the scope of the authority to search. See United States v. Robinson, 414 U.S. 218, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973); Stone v. State, 547 So. 2d 158 (Fla. 4th DCA 1989) (en banc); 2 W. LaFave, Search and Seizure §§ 5.2(a)-(c).
Reversed.
DANAHY, A.C.J., and FRANK and PATTERSON, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Alfonzo Allen v. State, 585 So. 2d 366 (Fla. 2d DCA 1991)…rug activity. The patdown of defendant provided a proper basis for such a belief. Under the circumstances, which included information that there were armed persons on the premises, the patdown was constitutionally permissible, see State v. Crawford, 565 So. 2d 859 (Fla. 2d DCA 1990), as was the temporary detention of defendant, see Wilson v. State, 547 So. 2d 215, 216 (Fla. 4th DCA 1989). Compare Smalls v. State, 581 So. 2d 1003 (Fla. 2d DCA 1991) (a search warrant authorizing the search on particular premis…
Authorities Cited
- United States v. Robinson, 414 U.S. 218 (U.S. 1973)
- State v. Boulia, 522 So. 2d 528 (Fla. 2d DCA 1988)
- Stone v. State, 547 So. 2d 158 (Fla. 4th DCA 1989)
- Cornett v. State, 547 So. 2d 158 (Fla. 4th DCA 1989)