Agreda v. State, 152 So. 3d 114

Detective in unmarked car conducting interdiction on divided U.S. Highway 27 (two lanes each direction, 65 mph limit, 40 mph minimum).
Detective observed a vehicle traveling 45 mph in the curb lane with several cars behind it; left lane was clear and traffic light.
Detective paced the vehicle for about half a mile, saw no weaving, drifting, mechanical signs, or medical distress, but believed the car was "impeding the flow of traffic."
Officer stopped the vehicle; driver had a suspended license; Agreda (passenger) also had suspended license and volunteered he had a gun; officer recovered firearm and later found crack cocaine and a pipe in the car.
Agreda moved to suppress evidence as fruit of an unlawful stop; trial court denied the motion, he pleaded no contest reserving appeal, was convicted of firearms and drug offenses; appellate court reversed and ordered discharge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was lawful under traffic statutes or the community-caretaking / safety exception	Agreda: stop unlawful because vehicle speed (45 mph) was within legal range and there were no articulable signs of vehicle/driver trouble	State: stop justified because vehicle was impeding traffic and officer reasonably could investigate possible medical/problematic driving	Stop was unlawful: neither statutory violation nor objective caretaking basis supported the stop; suppression denial reversed and convictions vacated

Connor v. State, 803 So. 2d 598 (Fla. 2001) (standard of review for suppression findings and legal application)
State, Dep't of Highway Safety & Motor Vehicles v. DeShong, 603 So. 2d 1349 (Fla. 2d DCA 1992) (community-caretaking can justify brief investigatory stop in some circumstances)
Holland v. State, 696 So. 2d 757 (Fla. 1997) (adopting objective-reasonableness test for traffic stops per Whren)
Whren v. United States, 517 U.S. 806 (1996) (objective-reasonableness standard for traffic stops)
Majors v. State, 70 So. 3d 655 (Fla. 1st DCA 2011) (caretaking stops must be supported by specific articulable facts)
Faunce v. State, 884 So. 2d 504 (Fla. 1st DCA 2004) (invalidating stop where vehicle traveled below speed limit absent other signs of trouble)
Bailey v. State, 319 So. 2d 22 (Fla. 1975) (upholding stop where weaving and below-speed travel suggested impairment)
State v. Davidson, 744 So. 2d 1180 (Fla. 2d DCA 1999) (stop justified where vehicle drifted and repeatedly corrected)
Jacoby v. State, 851 So. 2d 913 (Fla. 2d DCA 2003) (remedy: discharge when dispositive suppression ruling reversed on appeal)