STATE OF FLORIDA, APPELLANT,
v.
STANLEY SHADLER, APPELLEE
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Florida appeals the suppression of cocaine evidence obtained during a search incident to arrest for driving with a suspended license. The trial court suppressed the evidence based on State v. White, which bars evidence obtained from arrests based on erroneous information furnished by police or law enforcement agencies. The appellate court reverses, holding that the erroneous license suspension information came from non-law enforcement personnel in the Division of Driver's Licenses, not from law enforcement, and thus the exclusionary rule does not apply.
The court reversed the suppression order, holding that the erroneous information did not result from errors by police or law enforcement personnel. The Division of Driver's Licenses operates independently from the Florida Highway Patrol with separate organizational structure and leadership, and its employees are not law enforcement personnel. Therefore, the exclusionary rule does not apply, and the evidence should not be suppressed.
[1] Evidence seized as a result of an arrest based on erroneous information from a computer database is admissible if the error originated from non-law enforcement personnel.
[2] The exclusionary rule does not apply when an arrest is based on inaccurate information provided by a government agency, provided the inaccuracy does not stem from the fau…
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Join FLexlaw to unlock all legal intelligence“evidence should be suppressed where an arrest is based on erroneous information furnished by a police officer or agency”
States the rule from State v. White regarding when exclusionary rule applies to erroneous computer information
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Join FLexlaw to unlock all legal intelligenceA police officer arrested Shadler for driving with a suspended license based on erroneous information provided by the Florida Department of Highway Sa…
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W. SHARP, Judge.
The state appeals an order of the trial court which granted Shadler’s motion to suppress evidence of cocaine discovered by a police officer after a search incident to an arrest for driving with a suspended license. In concluding that the evidence should be suppressed, the trial court relied upon State v. White, 660 So. 2d 664 (Fla.1995). We reverse.
The trial court found that the arrest was based on information furnished to the police officer by the Florida Department of Highway Safety and Motor Vehicles (Department). In response to an inquiry by the police officer, the Department erroneously informed him that Shadler’s driver’s license had been suspended. In fact, Shadier completed an alcohol treatment course he had been ordered to attend and his license was reinstated. The trial court reasoned that because the Florida Highway Patrol is a law enforcement agency with law enforcement powers and is a division of the Department, the inaccuracy or failure to update computer records, was attributable to law enforcement personnel.
The Florida Supreme Court held in State v. White that evidence should be suppressed where an arrest is based on erroneous information furnished by a police officer or agency. The erroneous information in White stemmed from erroneous information in a computer in the sheriffs office. The court distinguished between situations where erroneous computer information results from clerical errors committed by court or non-law enforcement personnel and those resulting from errors committed by the police or law enforcement personnel.
The answer to the question of whether the exclusionary rule1 should be invoked to bar evidence seized as a result of an illegal arrest, apparently turns on whether the erroneous computer information results from errors committed by court employees or non-law enforcement personnel, or whether the information stems from police or law enforcement employees. Arizona v. Evans, 514 U.S. 1, 115 S.Ct. 1185, 131 L.Ed.2d 34 (1995); Bruno v. State, 704 So. 2d 134 (Pla. 1st DCA 1997); Bunse v. State, 661 So. 2d 389 (Fla. 5th DCA 1995).
We disagree with the trial court that the error in this case can be attributed to police or law enforcement personnel merely because the Department contains four divisions under the governor and cabinet of Florida, one of which is the Florida Highway Patrol (a law enforcement agency). The other three divisions, the Division of Driver’s Licenses, the Division of Motor Vehicles and the Division of Administrative Services, are independent from one another as well as the Florida Highway Patrol. Each has its own separate organizational structure and division director. The erroneous information came from the Division of Driver’s Licenses. Persons working for that division are not law enforcement personnel, but rather are more similar to the court employees in Arizona v. Evans.
REVERSED.
PETERSON and THOMPSON, JJ., concur. . U.S. Const, amend. IV; Art. I, § 12, Fla. Const.
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Shadler v. State, 761 So. 2d 279 (Fla. 2000)…ANSTEAD, J. We have for review State v. Shadler, 714 So. 2d 662 (Fla. 5th DCA 1998), which expressly and directly conflicts with the opinion in Bruno v. State, 704 So. 2d 134 (Fla. 1st DCA 1997). We have jurisdiction. See art. V, § 3(b)(3), Fla. Const. For the reasons that follow, we quash the decision in Shadle…
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Moore v. State, 123 So. 3d 672 (Fla. 2d DCA 2013)…s to case law specific to the issue. Both Mr. Moore’s attorney and the assistant state attorney came to the suppression hearing without conducting adequate research to assist the trial court. From the bench, the trial court located State v. Shadler, 714 So. 2d 662 (Fla. 5th DCA 1998) (Shadier I). Shadier I was seemingly on point and held that such errors by the Division of Driver Licenses were not errors by a “law enforcement agency” and, thus, did not render a stop based on such mistaken information unconsti…
Authorities Cited
- Arizona v. Evans, 514 U.S. 1 (U.S. 1995)
- State v. White, 660 So. 2d 664 (Fla. 1995)
- Bruno v. State, 704 So. 2d 134 (Fla. 1st DCA 1997)
- Bunse v. State, 661 So. 2d 389 (Fla. 5th DCA 1995)