LENUEL JOSIA VELAZQUEZ
v.
STATE OF FLORIDA

Fla. 6th DCA | 2026-11-06
No. 2025-2071
Leach, J., Nardella, J., White, J., Gannam, J.
2026 FL 15059 Florida District Court of Appeal, Sixth District (2026)

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Holding

Law enforcement officers, when acting outside their jurisdictions, retain the same capacity to make felony arrests as private citizens.


Headnotes

[1] Law enforcement officers retain authority to make felony arrests outside their jurisdictions based on the principle that such officers should not be less capable than pri…

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Key Quotes

“Common sense dictates that law enforcement officials, when they are outside their jurisdictions, should not be any less capable, by virtue of their position, of making a felony arrest than a private citizen.”

The court cited Phoenix v. State to support the principle that officers retain arrest authority outside their jurisdictions.

Facts & Procedural History

Lenuel Josia Velazquez appealed a conviction from the Circuit Court for Orange County, challenging a matter related to law enforcement authority.…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 6D2025-2071 Lower Tribunal No. 2024-CF-016675-A-O

LENUEL JOSIA VELAZQUEZ, Appellant,

V.

STATE OF FLORIDA, Appellee.

Appeal from the Circuit Court for Orange County. Barbara J. Leach, Judge.

November 6, 2026

PER CURIAM.

AFFIRMED. See Phoenix v. State, 455 So. 2d 1024, 1025 (Fla. 1984) ("Common sense dictates that law enforcement officials, when they are outside their jurisdictions, should not be any less capable, by virtue of their position, of making a felony arrest than a private citizen.").

NARDELLA, WHITE and GANNAM, JJ., concur.

Blair Allen, Public Defender, and Tosha Cohen, Assistant Public Defender, Bartow, for Appellant.

James Uthmeier, Attorney General, Tallahassee, and Zachary L. Wiseman, Assistant Attorney General, Daytona Beach, for Appellee.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING

AND DISPOSITION THEREOF IF TIMELY FILED

2


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