CLAYTON HARRIS, APPELLANT,

v.

STATE OF FLORIDA, APPELLEE

Citator

Cited By

• Harris v. State, 71 So. 3d 756 (Fla. 2011)
  …as a predicate for determining probable cause. The appellate courts addressing the issue in this state have differed on what evidence the State must present to meet its burden. The decision of the First District Court of Appeal in Harris v. State, 989 So. 2d 1214 (Fla. 1st DCA 2008), expressly and directly conflicts with the decisions of the Second District Court of Appeal in Gibson v. State, 968 So. 2d 631 (Fla. 2d DCA 2007), and Matheson v. State, 870 So. 2d 8 (Fla. 2d DCA 2003).2 In Harris, the First Dist…
• Frost v. State, 53 So. 3d 1119 (Fla. 4th DCA 2011)
  …the trial court. Id. at 336 (citations omitted) (following Dawson v. State, 238 Ga.App. 263, 518 S.E. 2d 477 (1999)). We certified direct conflict with Matheson. Id. Laveroni has been followed by the First and Fifth Districts. See Harris v. State, 989 So. 2d 1214 (Fla. 1st DCA 2008); State v. Coleman, 911 So. 2d 259 (Fla. 5th DCA 2005). The Supreme Court granted review in Harris to resolve the inter-district conflict and held oral argument on June 4, 2009. See Docket, Harris v. State, 989 So. 2d 1214. The co…

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• Wiggs v. State, 72 So. 3d 154 (Fla. 2d DCA 2011)
  …rict courts. The First, Fourth, and Fifth Districts had held that the State could establish a prima facie case of probable cause by providing evidence of the drug-detection dog’s proper training and certification. Id. at 762 (citing Harris v. State, 989 So. 2d 1214, 1215 (Fla. 1st [*158] DCA 2008); State v. Laveroni, 910 So. 2d 333, 336 (Fla. 4th DCA 2005); State v. Coleman, 911 So. 2d 259, 261 (Fla. 5th DCA 2005)). The prima facie case of probable cause could be rebutted by the defendant’s presentation of evi…

Authorities Cited

• Matheson v. State, 870 So. 2d 8 (Fla. 2d DCA 2003)
• State v. Laveroni, 910 So. 2d 333 (Fla. 4th DCA 2005)
• State v. Coleman, 911 So. 2d 259 (Fla. 5th DCA 2005)
• Gibson v. State, 968 So. 2d 631 (Fla. 2d DCA 2007)