SCOTT CAMERON HART, PETITIONER,
v.
STATE OF FLORIDA, RESPONDENT
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Hart challenges a circuit court's reversal of a county court's suppression of blood alcohol test results. The District Court of Appeal holds that the circuit court impermissibly reweighed factual findings rather than applying the correct appellate standard, which requires deference to the trial court's factual determinations.
A circuit court acting as an appellate court cannot reweigh factual findings made by the trial court. The trial court's ruling on a motion to suppress is entitled to a presumption of correctness, and the reviewing court must interpret evidence in a manner most favorable to sustaining the trial court's ruling.
[1] An appellate court reviewing a motion to suppress ruling cannot reweigh the facts presented at the suppression hearing to reach a contradictory conclusion.
[2] A trial court's ruling on a motion to suppress is presumed correct on appellate review.
Previewing 2 of 5 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“the state failed to meet its burden of showing that at the time the police officer requested the blood draw the officer had reasonable grounds to believe that the Defendant had contributed to the accident”
The county court's factual finding that justified suppression of the blood test results.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceHart was involved in a fatal motor vehicle accident. A police officer ordered Hart's blood drawn without conducting a field sobriety test or detaining…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Standard Of Review For Suppression Motions cases and more on FLexlaw
PER CURIAM.
Scott Cameron Hart has petitioned this court for certiorari review of an order of the circuit court, acting in its appellate capacity, which quashed a county court order granting a motion to suppress the results of a blood alcohol test. Hart argues that, as a reviewing court, the circuit court is prohibited from reweighing the facts presented at the motion to suppress hearing in order to reach a contradictory conclusion and we agree.
Hart was involved in a motor vehicle accident in which a fatality occurred. The police officer responding to the scene ordered that Hart’s blood be drawn, but did not conduct a field sobriety test or detain Hart. After being charged by information approximately one year later, Hart moved to suppress the results of the blood draw. Ultimately, the trial court conducted a hearing on the motion to determine whether the police officer had reasonable grounds to believe, at the time he requested the blood draw, that Hart had contributed to the accident.
In granting the motion to suppress, the court specifically concluded that “the state failed to meet its burden of showing that at the time the police officer requested the blood draw the officer had reasonable grounds to believe that the Defendant had contributed to the accident_ [VJirtually all of the testimony and the basis of all opinions rendered by the police officer were from information gathered or derived subsequent to the blood draw.” The court relied on Magaw v. State, 537 So. 2d 564 (Fla.1989).
The detañed order explained that between the time of the accident and the filing of the information, the state had engaged an engineering firm to conduct an accident investigation. That subsequent investigation, the court determined, improperly formed the basis for the officer’s conclusion that Hart had contributed to the accident.
On appeal, the circuit court reversed, finding that the evidence presented at the hearing was sufficient to warrant the request for the blood draw. Unlike the trial court, the circuit court placed great weight on the testimony of the responding officer who, in examining the damage to the victim’s car, concluded that Hart had contributed to the accident by travelling at a higher rate of speed than that posted. The circuit court found that such a “deviation or lack of care” coupled with the fact that the accident was fatal to the other driver, justified the taking of blood to test for impairment, the results of which would be admissible.
Our review of the record before us indicates that the county court carefully considered the facts presented at the hearing and made a determination of admissibility, based on the prevailing standard as enunciated in Magaw. Such a factual issue was proper for the county court, and not the circuit court acting in its appellate capacity, to resolve. See, e.g. Gilbert v. State, 629 So. 2d 957 (Fla. 3d DCA 1993).
The circuit court reached a different conclusion because it attributed more significance to certain facts or testimony than did the county court. The appellate review afforded by the circuit court in this instance was tantamount to an impermissible reweighing of the facts. The law is well-settled that a trial court’s ruling on a motion to suppress is before a reviewing court “clothed with a presumption of correctness, and the reviewing court must interpret the evidence and reasonable inferences and deductions derived therefrom in a manner most favorable to sustain the trial court’s ruling.” Owen v. State, 560 So. 2d 207, 210 (Fla.1990).
Accordingly, we grant the petition, issue the writ and quash the order of the circuit court with instructions that the order of the county court be affirmed.
RYDER, A.C.J., and CAMPBELL and BLUE, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Maurer v. State, 668 So. 2d 1077 (Fla. 5th DCA 1996)…. State v. Paul, 638 So. 2d 537 (Fla. 5th DCA 1994), rev. denied, 654 So. 2d 131 (Fla. 1995). The circuit court sitting in its appellate capacity may not reweigh the evidence or substitute its judgment for that of the fact-finder. See Hart v. State, 661 So. 2d 54 (Fla. 2d DCA 1995) (holding that circuit court is prohibited from reweighing facts presented at suppression hearing, and that circuit court may not attribute more significance to certain facts than county court in order to reach contradictory conclu…
-
State v. Hunton, 699 So. 2d 320 (Fla. 2d DCA 1997)…orrectness, and the reviewing court must interpret the evidence and reasonable inferences and deductions derived therefrom in a manner most favorable to sustain the trial court’s ruling.” Owen v. State, 560 So. 2d 207, 210 (Fla.1990); Hart v. State, 661 So. 2d 54 (Fla. 2d DCA 1995). In this case, the record contains evidence to support the trial court’s rulings on both issues involved in the motion to suppress. On appeal, the State not only argues the issue of consent but also argues that the doctrine of in…
-
Sunby v. State, 845 So. 2d 1006 (Fla. 5th DCA 2003)…627 So. 2d 1257 (Fla. 3d DCA 1993). Like the District Court of Appeal, the circuit court sitting in its appellate capacity cannot reweigh the evidence and choose to believe a state witness which the county court chose not to believe. Hart v. State, 661 So. 2d 54 (Fla. 2d DCA 1995); Maurer. Here the circuit court did just that. In seeking to sustain the circuit court decision, the state claims the county court “ignored relevant facts” and thus misapplied the appropriate rule of law. But the county court as…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Owen v. State, 560 So. 2d 207 (Fla. 1990)
- Magaw v. State, 537 So. 2d 564 (Fla. 1989)
- Gilbert v. State, 629 So. 2d 957 (Fla. 3d DCA 1993)
- Pickard v. City OF Vero Beach, 629 So. 2d 957 (Fla. 4th DCA 1993)