STATE OF FLORIDA, APPELLANT,
v.
CHARLES T. STACHELL, APPELLEE
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The State appeals a trial court's order suppressing evidence obtained during a traffic stop of Charles Stachell's vehicle. The appellate court reverses, holding that the stop was valid because the officers observed an expired license tag, providing an objective basis for the stop regardless of any subjective intent to investigate suspected drug activity.
The stop was valid because the officers had probable cause based on the expired license tag violation under Florida Statute section 320.07(3), and the validity of such a stop is not questionable even where the officer may believe the motorist has engaged in other illegal conduct. The subjective intent of the officer does not invalidate an otherwise lawful traffic stop.
[1] A traffic stop is valid if based on a violation of traffic laws, regardless of the officer's subjective intent or suspicion of other illegal activity.
[2] The validity of a vehicle stop is not undermined by an officer's ulterior motive if the stop is otherwise supported by probable cause for a traffic violation.
Previewing 2 of 4 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 validity of such a stop is not questionable even where the officer may believe the motorist has engaged in other illegal conduct. Whren v. United States”
Establishes that objective basis for stop is valid regardless of officer's subjective beliefs about other crimes
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceOfficers on patrol near 29th Street and Lake Avenue observed Stachell's parked vehicle with two male occupants and noticed a third male on a bicycle a…
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QUINCE, Judge.
The State of Florida challenges an order entered by the trial court granting Charles Stachell’s motion to suppress evidence. We reverse the suppression order because the stop of Stachell’s vehicle was based on a violation of the traffic laws and was therefore valid.
The arresting officers testified at the suppression hearing that they were-on patrol in the area surrounding 29th Street and Lake Avenue in Hillsborough County, Florida, when they noticed Stachell’s parked vehicle. Stachell was in the driver’s seat and another male occupied the passenger seat. They saw a third male approach the vehiclé on a bicycle. This person looked nervously over his shoulder at the officers and left after a few moments. Stachell drove off. The officers followed and saw the car park on 29th Street. The male on the bicycle again approached the car. One of the officers believed a narcotics transaction was in progress. The three individuals separated in different groups, and regrouped around the corner out of the officers’ line of vision. The officers decided to watch them but did not observe a drug transaction.
Again, Stachell drove away, and the officers followed. They had decided to conduct a field interview if Stachell drove to another drug location. As the officers followed Stac-hell, they noticed his tag had expired. After stopping the vehicle, they approached the car and one officer observed what he believed to be a piece of rock cocaine inside the vehicle. Stachell was arrested and charged with possession of cocaine, driving while license can-celled, suspended or revoked and driving an unregistered vehicle. A motion to suppress was filed, and the trial court granted the motion finding the officers had formed an intent to conduct a field interview before they observed the expired tag, and this observation did not validate the stop.
The officers were clearly authorized to stop Staehell’s vehicle since his tag had expired, a violation of section 320.07(3), Florida Statutes (1995). Moreover, the validity of such a stop is not questionable even where the officer may believe the motorist has engaged in other illegal conduct. Whren v. United States, — U.S. —, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996). In Whren the Supreme Court reiterated the principle that the subjective intent of the officer does not make otherwise lawful conduct illegal or unconstitutional. See Scott v. United States, 436 U.S. 128, 98 S.Ct. 1717, 56 L.Ed.2d 168 (1978). As the Court indicated, an ulterior motive does not strip the officers of legal justification for the stop.
Thus, while these officers may have had another subjective reason for effectuating this stop, they nonetheless had probable cause for the stop based on a violation of the traffic laws. The order suppressing the evidence is hereby reversed, and this case is remanded to the trial court for farther proceedings.
PARKER, A.C.J., and LAZZARA, J., concur.
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Citator
Cited By
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Gomez v. State, 748 So. 2d 352 (Fla. 3d DCA 1999)…that it is dependent on the simple objective test of whether the officer had probable cause to believe that the defendant violated a traffic code)(citing Whren v. U.S., 517 U.S. 806, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996)); [*353] State v. Stachell, 681 So. 2d 802 (Fla. 2d DCA 1996). Further, the seizure was lawful because the defendant voluntarily gave the officer consent to search the car for his registration and insurance card. Denehy v. State, 400 So. 2d 1216 (Fla.1980). Affirmed.…
Authorities Cited
- Whren v. United States, 517 U.S. 806 (U.S. 1996)
- Scott v. United States, 436 U.S. 128 (U.S. 1978)