RONALD LEAGUE, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Ronald League challenges his conviction for cocaine possession, arguing the police lacked probable cause to seize him. The court affirms, holding that an anonymous tip that a known drug dealer was selling narcotics was sufficiently corroborated by officers' independent observation of a hand-to-hand transaction involving money and a small object.
The court held that the anonymous tip was sufficiently corroborated by the officers' independent observation of a hand-to-hand transaction involving a known drug dealer where money was exchanged for a small object, establishing probable cause for League's seizure.
[1] An anonymous tip, when independently corroborated by observed activity consistent with criminal conduct, can establish probable cause for a seizure.
[2] Probable cause to arrest or search exists when the totality of the facts and circumstances within an officer's knowledge sufficiently warrant a reasonable person to belie…
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Join FLexlaw to unlock all legal intelligence“While anonymous tips are not in and of themselves sufficient to constitute either reasonable suspicion or probable cause, when independent investigation reveals corroboration of the substance of the tip, the totality of the circumstances may rise to either reasonable suspicion or probable cause.”
Establishes the legal standard for when anonymous tips may support probable cause
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceDetective Rivers received an anonymous complaint that Robert Hoskkins ("Peanut") was selling narcotics at his residence. Rivers knew Peanut had been a…
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WARNER, C.J.
Appellant challenges his conviction for purchase and possession of cocaine on the ground that the police stopped and seized him without probable cause. We hold that the anonymous tip on which the police acted was confirmed and independently corroborated by the activity they witnessed prior to seizing appellant. Therefore, the seizure did not violate the Fourth Amendment.
Detective Rivers, an eleven year veteran of the Vero Beach Police Deportment and a member of the county’s Multi-Agency Criminal Enforcement Unit, received an anonymous complaint that Robert Hors-kins, known as “Peanut,” was selling narcotics at his residence. Although Rivers had previously received numerous complaints regarding Peanut, and knew that he had been previously arrested for drug dealing, Rivers had not had the time to investigate him. Rivers and other detectives went to the residence and hid in the bushes to observe the location from fifteen or twenty feet away. After about twenty or thirty minutes with no activity, Rivers observed appellant drive up, get out of his vehicle, and approach the house. Appellant knocked on the door, Peanut came out, they talked, and appellant handed Peanut money. Peanut briefly went back inside, and when he came back out, he dropped something small into appellant’s left hand. Rivers recognized Peanut when he exited the residence. Rivers then instructed one of the other officers to seize appellant. As appellant got back into his vehicle, the officer grabbed appellant’s clenched left hand and a couple of pieces of what tested positive for cocaine fell out. Appellant was arrested.
Whether the facts as found by the trial court constitute probable cause for arrest requires de novo review on appeal. See Ornelas v. United States, 517 U.S. 690, 699, 116 S.Ct. 1657, 134 L.Ed.2d 911 (1996). Probable cause to arrest or search exists when the totality of the facts and circumstances within an officer’s knowledge sufficiently warrant a reasonable person to believe that, more likely than not, a crime has been committed. See Curtis v. State, 748 So. 2d 370, 374 (Fla. 4th DCA 2000). “Articulating precisely what ‘reasonable suspicion’ and ‘probable cause’ mean is not possible. They are commonsense, nontechnical conceptions that deal with ‘the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act.’ ” Ornelas, 517 U.S. at 695, 116 S.Ct. 1657 (quoting Illinois v. Gates, 462 U.S. 213, 231, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983)).
In this case, the officers received an anonymous tip that Peanut was selling drugs at his home. Peanut was known to the police and numerous complaints had been made. Although the substance of those complaints was not revealed in the officer’s testimony, the officer knew that Peanut had been arrested for drug activity. While anonymous tips are not in and of themselves sufficient to constitute either reasonable suspicion or probable cause, when independent investigation reveals corroboration of the substance of the tip, the totality of the circumstances may rise to either reasonable suspicion or probable cause. See J.L. v. State, 727 So. 2d 204, 206 (Fla.1998), aff'd, 529 U.S. 266, 120 S.Ct. 1375, 146 L.Ed.2d 254 (2000); Cunningham v. State, 591 So. 2d 1058, 1061 (Fla. 2d DCA 1991) (independent evidence of criminal activity apart from verified tip needed to support search and seizure). The anonymous tip in this case was corroborated by the independent observation of conduct consistent with a drug transaction. Specifically, a trained officer witnessed a hand to hand transaction involving a known drug dealer where money was exchanged for a small object. We thus conclude that there was probable cause for appellant’s seizure. See Revels v. State, 666 So. 2d 213 (Fla. 2d DCA 1995). See also Williams v. State, 717 So. 2d 1109, 1109-10 (Fla. 5th DCA 1998); Knox v. State, 689 So. 2d 1224, 1225-6 (Fla. 5th DCA 1997).
Affirmed.
TAYLOR and HAZOURI, JJ., concur.
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State v. Hankerson, 65 So. 3d 502 (Fla. 2011)…277 (Fla. 4th DCA 2006); Walker v. State, 846 So. 2d 643 (Fla. 2d DCA 2003); Glover v. State, 843 So. 2d 919 (Fla. 5th DCA 2003); Belsky v. State, 831 So. 2d 803 (Fla. 4th DCA 2002); Ford v. State, 783 So. 2d 284 (Fla. 2d DCA 2001); League v. State, 778 So. 2d 1086 (Fla. 4th DCA 2001); State v. Gandy, 766 So. 2d 1234 (Fla. 1st DCA 2000); D.A.H. v. State, 718 So. 2d 195 (Fla. 2d DCA 1998); State v. K.S., 694 So. 2d 104 (Fla. 5th DCA 1997); Burnette v. State, 658 So. 2d 1170 (Fla. 2d DCA 1995); Walker v. State,…
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Harder v. Edwards, 174 So. 3d 524 (Fla. 4th DCA 2015)…facts and circumstances within an officer’s knowledge sufficiently warrant a reasonable person to believe that, more likely than not, a crime has been committed.’ ” Santiago v. State, 84 So. 3d 455, 459 (Fla. 4th DCA 2012) (quoting League v. State, 778 So. 2d 1086, 1087 (Fla. 4th DCA 2001)). ‘“In dealing with probable cause, ... as the very name implies, we deal with probabilities. These are not technical; they are the .factual and practical considerations of everyday life on which reasonable and prudent men,…
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State v. Blaylock, 76 So. 3d 13 (Fla. 4th DCA 2011)…e. “Probable cause to arrest or search exists when the totality of the facts and circumstances within an officer’s knowledge sufficiently warrant a reasonable person to believe that, more likely than not a crime has been committed.” League v. State, 778 So. 2d 1086, 1087 (Fla. 4th DCA 2001). Even though the detective in this case acknowledged that the [*15] substance, although appearing to emit crack cocaine smoke, could theoretically have been tobacco, this is not dispositive as to whether the detective had p…
Previewing 3 of 10 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Illinois v. Gates et ux., 462 U.S. 213 (U.S. 1983)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996)
- Florida v. J. L., 529 U.S. 266 (U.S. 2000)
- J.L. v. State, 727 So. 2d 204 (Fla. 1998)
- Curtis v. State, 748 So. 2d 370 (Fla. 4th DCA 2000)
- Revels v. State, 666 So. 2d 213 (Fla. 2d DCA 1995)
- Cunningham v. State, 591 So. 2d 1058 (Fla. 2d DCA 1991)
- Knox v. State, 689 So. 2d 1224 (Fla. 5th DCA 1997)
- Quincy Williams v. State, 717 So. 2d 1109 (Fla. 5th DCA 1998)