STATE OF FLORIDA, APPELLANT,
v.
ALLEN C. HADDEN, APPELLEE
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Florida appeals a trial court's suppression order for methamphetamine seized from Hadden during a traffic stop. The appellate court reversed, holding that a confidential informant's detailed information, combined with the informant's established reliability, provided reasonable suspicion to justify the investigatory stop.
The court held that the confidential informant's detailed information, given the informant's established six-month relationship with the officer and 25+ prior reliable tips, provided sufficient reasonable suspicion to justify the investigatory stop. The discovery of the methamphetamine in plain view on Hadden's license thereafter gave the officer probable cause.
[1] Information from a reliable confidential informant, even if not corroborated by independent police work, can establish reasonable suspicion for an investigatory stop.
[2] The totality of the circumstances, including detailed information from a confidential informant about a vehicle and its occupants, can justify an investigatory stop.
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Join FLexlaw to unlock all legal intelligence“information received from a confidential informant must consist of enough details to provide the officers with reasonable suspicion to justify a stop, it does not fall under the same scrutiny as information received from an anonymous caller”
Establishes the legal standard for evaluating confidential informant tips, which receive less scrutiny than anonymous sources.
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Join FLexlaw to unlock all legal intelligenceAn officer received a phone call from a confidential informant who had worked with the officer for six months and provided reliable information leadin…
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PARKER, Judge.
The State of Florida appeals the trial court’s order granting Allen C. Hadden’s motion to suppress methamphetamine seized from Hadden. We conclude that the trial court erred by suppressing the evidence because under the totality of the circumstances the officers had a reasonable suspicion which permitted this investigatory stop.
The officer in this case received a phone call from a confidential informant. The confidential informant had worked with this officer for approximately six months and had provided reliable information at least twenty-five times which led to several possession arrests, as well as arrests in other criminal cases. While information received from a confidential informant must consist of enough details to provide the officers with reasonable suspicion to justify a stop, it does not fall under the same scrutiny as information received from an anonymous caller. See State v. Evans, 620 So. 2d 802, 803 (Fla. 2d DCA 1993); State v. Edwards, 547 So. 2d 183 (Fla. 2d DCA 1989).
In this case, the confidential informant provided the officer with the following information: the name of the person driving the car; that there was a passenger; a description of the car including the make, color, year, tag number; and the fact that the tag light was inoperable. The confidential informant also told the officer that the suspects would have the drug methamphetamine, which they picked up in Mulberry, and that the suspects were heading to Winter Haven via route 540A. Within an hour of the call, the officers checked the license number information, checked the driver’s residence to be sure that the car was not at home, and then positioned themselves on route 540A to wait for the suspects. Within a few minutes, the officers spotted and stopped the car matching the description given by the confidential informant.
Both the driver and Hadden exited the car. The officer requested identification and ran a check on the driver. The computer results matched the information that the confidential informant had furnished to the officer. A K-9 unit conducted a search, and the officers arrested the driver for possession of marijuana. The officers then asked Hadden for identification. Hadden handed the officer his license which had a small clear bag stuck to the back. A narcotics’ field test on the substance in the bag revealed that the bag contained methamphetamine, again confirming the information provided by the confidential informant.
We conclude that the information provided by the confidential informant gave the officers sufficient reasonable suspicion to justify the investigatory stop of the vehicle. When Hadden dropped the clear bag in plain view of the officer, this gave the officer probable cause to believe that Hadden was involved in criminal activity. See State v. Hetland, 366 So. 2d 831 (Fla. 2d DCA 1979), approved, 387 So. 2d 963 (Fla.1980). We, therefore, reverse the trial court’s order suppressing the methamphetamine seized from Hadden and remand this case for further proceedings.
Reversed and remanded.
DANAHY, A.C.J., and ALTENBERND, J., concur.
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Darry Chaney v. State, 956 So. 2d 535 (Fla. 4th DCA 2007)…; see also State v. Talbott, 425 So. 2d 600, 602 (Fla. 4th DCA 1982). It does not fall under the same scrutiny as information received from an anonymous tipster. See Austin v. State, 640 So. 2d 1247, 1248 (Fla. 5th DCA 1994) (citing State v. Hadden, 629 So. 2d 1043 (Fla. 2d DCA 1993)). Appellant argues that the informant in this case was merely an anonymous tipster because, among other things, the officer had never met him before and did not include any identifying information about him in her police report. H…
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Maynard v. State, 742 So. 2d 315 (Fla. 2d DCA 1999)…lished that a confirmed tip from an informant who has provided reliable information in the past provides reasonable suspicion to stop a [*317] person suspected of criminal activity. See J.L. v. State, 727 So. 2d 204, 206 (Fla.1998); State v. Hadden, 629 So. 2d 1043, 1043-44 (Fla. 2d DCA 1993). Reasonable suspicion also arises from confirmed information provided by a citizen-informant. See Grant v. State, 718 So. 2d 238, 239-40 (Fla. 2d DCA 1998). However, tips from anonymous informants must be confirmed and su…
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Austin v. State, 640 So. 2d 1247 (Fla. 5th DCA 1994)…abama v. White, 496 U.S. 325, 110 S.Ct. 2412, 110 L.Ed.2d 301 (1990)). Courts have held that information received from a confidential informant does not fall under the same scrutiny as information received from an anonymous caller. State v. Hadden, 629 So. 2d 1043 (Fla. 2d DCA 1993). The citizen source who provides identification and presents information in person can be better evaluated by a police officer than an unknown voice over the telephone. Thus, any slight weaknesses in the factual information or the…
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
- Hetland v. State, 387 So. 2d 963 (Fla. 1980)
- State v. Hetland, 366 So. 2d 831 (Fla. 2d DCA 1979)
- State v. Edwards, 547 So. 2d 183 (Fla. 2d DCA 1989)
- State v. Mac Dale Evans, 620 So. 2d 802 (Fla. 2d DCA 1993)