STATE OF FLORIDA, APPELLANT,
v.
KEITH GARRETT SNEAD, APPELLEE
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The court held that the objective test for traffic stops requires only probable cause, not inquiry into the officer's subjective motivation.
Officer stopped Snead's vehicle due to an inoperable taillight and brake light, issuing a citation for improper equipment. Evidence of a firearm and c…
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PATTERSON, Judge.
The State appeals from an order suppressing evidence of a firearm and cocaine found in Keith Snead’s vehicle after a traffic stop. The trial court determined the stop was pre-textual. We reverse.
In determining the validity of a traffic stop, the United States Supreme Court in Whren v. United States, 517 U.S. 806, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996), held that an objective test is to be applied, thereby overruling the reasonable officer test of State v. Daniel, 665 So. 2d 1040 (Fla.1995). See Holland v. State, 696 So. 2d 757 (Fla.1997). “As a general matter, the decision to stop an automobile is reasonable where the police have probable cause to believe that a traffic violation has occurred.” Whren, 517 U.S. at 808, 116 S.Ct. at 1772. Thus, in “applying the objective test, generally the only determination to be made is whether probable cause existed for the stop in question.” Holland, 696 So. 2d at 759 (footnote omitted).
Here, Officer Ober, who stopped Snead’s vehicle, testified that the taillight and brake light on the driver’s side were inoperable. He issued Snead a traffic citation for “improper unsafe equipment.” The evidence showed that the officer had probable cause to make the stop. No further inquiry into the officer’s motivation for the stop is relevant under the objective test. See Holland, 696 So. 2d at 760 (stating that “subjective viewpoints no longer factor into the analysis”). Therefore, we reverse the suppression order and remand for further proceedings.
Reversed and remanded.
PARKER, C.J., and NORTHCUTT, J., concur.
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Tristan Hilton v. State, 961 So. 2d 284 (Fla. 2007)…of a vehicle is proper even if the equipment violation does not create an unduly hazardous operating condition.”). A stop is lawful under section 316.610 where the vehicle reasonably appears to have an equipment violation. See, e.g., State v. Snead, 707 So. 2d 769, 770 (Fla. 2d DCA 1998) (holding that stop was reasonable where officer had probable cause to believe that appellee’s taillight and brake light were inoperable). Schuck, 913 So. 2d at 71. For all of the above reasons, I would approve the decision o…
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State v. Kindle, 782 So. 2d 971 (Fla. 5th DCA 2001)…1999); see also Saviory v. State, 717 So. 2d 200 (Fla. 5th DCA 1998) (concluding that officers had reasonable basis for a stop of vehicle where license tag was not readable as required by law), rev. denied, 729 So. 2d 394 (Fla.1999); State v. Snead, 707 So. 2d 769 (Fla. 2d DCA 1998) (finding that officer had probable cause to make a traffic stop where he observed that a taillight and a brake light on the driver’s side were inoperable). Florida courts have consistently held that a traffic stop must last no lo…
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Tristan Hilton v. State, 901 So. 2d 155 (Fla. 2d DCA 2005)…Whren, this court held that the stop was reasonable because the officers had probable cause to believe that the truck had a dim tag light, even though the officers may have been looking for drug traffic that evening. Id. at 878; see State v. Snead, 707 So. 2d 769, 770 (Fla. 2d DCA 1998) (holding that stop was reasonable where officer had probable cause to believe that appellee’s taillight and brake light were inoperable); State v. Moore, 791 So. 2d 1246 (Fla. 1st DCA 2001) (concluding that where police were…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Whren v. United States, 517 U.S. 806 (U.S. 1996)
- Holland v. State, 696 So. 2d 757 (Fla. 1997)
- State v. Daniel, 665 So. 2d 1040 (Fla. 1995)