MIKEAL GLENNDALE HAMILTON
v.
STATE OF FLORIDA

Fla. 6th DCA | 2025-09-05
No. 2024-1342
Brownlee, J., Stargel, J., Nardella, J., Carter, J.
2025 FL 7727 Florida District Court of Appeal, Sixth District (2025)

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Holding

An officer may conduct a traffic stop based on reasonable suspicion that a vehicle is being operated in an unusual manner indicating the driver is injured, ill, or impaired, even without observing a traffic infraction.


Headnotes

[1] An officer may conduct a traffic stop based on reasonable suspicion that a vehicle is being operated in an unusual manner indicating impairment or incapacity, even withou…

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Key Quotes

“Florida law is clear that an officer is justified in stopping a vehicle even in the absence of a traffic infraction when the vehicle is being operated in an unusual manner causing legitimate concern for the safety of the public.”

Court citing State v. Sheldon, 394 So. 3d 1263, 1265 (Fla. 5th DCA 2024)

Facts & Procedural History

Hamilton was stopped by an officer who observed his vehicle being operated in an unusual manner. Hamilton subsequently pled no contest to driving unde…

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Opinion of the Court
Brownlee

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

_____________________________

Case No. 6D2024-1342 Lower Tribunal No. 2024-CT-400416-A-O _____________________________

MIKEAL GLENNDALE HAMILTON, Appellant, v. STATE OF FLORIDA, Appellee. _____________________________

Appeal from the County Court for Orange County. Amy J. Carter, Judge.

September 5, 2025

BROWNLEE, J.

Mikeal Hamilton pled no contest to driving under the influence and reserved the right to appeal the denial of his dispositive motion to suppress evidence obtained during a traffic stop. Because the dash-cam video and other record evidence supports the court’s conclusion that Hamilton’s driving pattern gave the officer reasonable suspicion to believe he was injured, ill, or otherwise impaired, we affirm. See, e.g., State v. Sheldon, 394 So. 3d 1263, 1265 (Fla. 5th DCA 2024) (“Florida law is clear that an officer is justified in stopping a vehicle even in the absence of a traffic

2

infraction when the vehicle is being operated in an unusual manner causing legitimate concern for the safety of the public.”).

AFFIRMED.

STARGEL and NARDELLA, JJ., concur.

Blair Allen, Public Defender, and William L. Sharwell, Assistant Public Defender, Bartow, for Appellant.

James Uthmeier, Attorney General, Tallahassee, and Marissa V. Giles, Assistant Attorney General, Daytona Beach, for Appellee.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING

AND DISPOSITION THEREOF IF TIMELY FILED


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