JOANN CRAWFORD, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Joann Crawford was convicted of two felony counts of drug possession after pleading nolo contendere. She appealed the trial court's denial of her motion to suppress evidence obtained during a warrantless search, arguing the police lacked probable cause based on an uncorroborated confidential informant tip.
The trial court properly denied the motion to suppress because substantial competent evidence supported its ruling. Under Florida law, an officer need not have first-hand knowledge of probable cause but may rely on information from a person reasonably believed to be truthful, and the facts here satisfied that standard.
[1] A trial court's ruling on a motion to suppress is presumed correct on appeal, and evidence must be interpreted in the light most favorable to sustaining the trial court's…
[2] A police officer may arrest without a warrant if they reasonably believe a felony has been or is being committed and the person to be arrested committed or is committing…
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Join FLexlaw to unlock all legal intelligence“The trial court's ruling on a motion to suppress comes to this court with a presumption of correctness, and in testing the accuracy of the trial court's conclusions, we should interpret the evidence and all reasonable inferences and deductions to be drawn therefrom in a light most favorable to sustain these conclusions.”
Establishes the standard of review for suppression rulings, requiring deference to trial court findings
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Join FLexlaw to unlock all legal intelligenceCrawford was charged with two counts of possession of a controlled substance. Police conducted a search and seizure without a warrant based on informa…
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PER CURIAM.
The appellant, Joann Crawford, was charged by information with two felony counts of possession of a controlled substance. She entered a plea of not guilty and filed a motion to suppress on the grounds that the evidence was obtained pursuant to an unreasonable search and seizure. After hearing testimony and argument, the trial judge denied the motion to suppress. Appellant Crawford changed her plea to nolo contendere, reserving her right to appeal the denial of the motion to suppress and the court entered a judgment of conviction and sentence of two concurrent four-month terms in the Dade County Jail.
On appeal, Crawford contends that the trial court erred in denying the motion to suppress evidence seized by the police without a warrant where there was no showing of the underlying circumstances on which the officer based his conclusion that the information received from a confidential informant was accurate, and where there was no independent evidence upon which to base probable cause.
The trial court’s ruling on a motion to suppress comes to this court with a presumption of correctness, and in testing the accuracy of the trial court’s conclusions, we should interpret the evidence and all reasonable inferences and deductions to be drawn therefrom in a light most favorable to sustain these conclusions. Rodriguez v. State, Fla.App.1966, 189 So. 2d 656, concurring opinion of Judge Barkdull, 660. Under § 901.15, a police officer may make an arrest without a warrant when he reasonably believes that a felony has been or is being committed and reasonably believes that the person to be arrested has committed or is committing it. The arresting officer is not required to have sufficient first hand knowledge to constitute probable cause. It is sufficient if the police officer initiating the chain of communication either had first hand knowledge or received his information from some person, official source or eye witness, who it seems reasonable to believe is telling the truth. Salas v. State, Fla.App.1971, 246 So. 2d 621, 622.
Having examined the facts pursuant to the foregoing principles of law, we find there to be substantial competent evidence to support the trial court’s ruling. See Eason v. State, Fla.App.1975, 317 So. 2d 447.
Affirmed.
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Citator
Cited By (15 total)
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Bettez v. The City OF Miami, 510 So. 2d 1242 (Fla. 3d DCA 1987)…ek to have the plaintiff criminally prosecuted; a summary judgment for the defendant City of Miami was, therefore, entirely appropriate in this case. See DeMarie v. Jefferson Stores, Inc., 442 So. 2d 1014, 1017 (Fla. 3d DCA 1983); Crawford v. State, 334 So. 2d 141 (Fla. 3d DCA 1976); Salas v. State, 246 So. 2d 621 (Fla. 3d DCA 1971). The final summary judgment under review is, in all respects, Affirmed.…
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Carroll v. State, 497 So. 2d 253 (Fla. 3d DCA 1985)…the police officer initiating the chain of communication either had first hand [sic] knowledge or received his information from some person, official source or eye witness, who it seems reasonable to believe is telling the truth. Crawford v. State, 334 So. 2d 141, 142 (Fla. 3d DCA 1976). See also Salas v. State, 246 So. 2d 621, 622 (Fla. 3d DCA 1971) and cases cited. See generally 1 W. LaFave, Search and Seizure § 3.5(b) (1978). Cf. United States v. Hensley, 469 U.S. 221,105 S.Ct. 675, 83 L.Ed.2d 604 (1985)…
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Polk v. Dorothea Williams, 565 So. 2d 1387 (Fla. 5th DCA 1990)…and knowledge to constitute probable cause. It is sufficient if an officer initiating the chain of communication receives information from an official source or eyewitness who, it seems reasonable to believe, is telling the truth. Crawford v. State, 334 So. 2d 141 (Fla. 3rd DCA 1976). This so-called “fellow officer” rule has been applied to search warrants, as well as arrests. “Observations of fellow officers of the government engaged in a common investigation are plainly a reliable basis for a warrant applie…
Previewing 3 of 15 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Onelio Garcia Rodriquez v. State, 189 So. 2d 656 (Fla. 3d DCA 1966)
- Salas v. State, 246 So. 2d 621 (Fla. 3d DCA 1971)
- Eason v. State, 317 So. 2d 447 (Fla. 3d DCA 1975)