Alt v. State, 63 So. 3d 855

Officer Mandell approached A.L.T. when he did not see the bicycle’s registration mark.
A.L.T. consented to a search for weapons or drugs, which led to the wallet being removed and searched.
In the wallet, officers found an ID card, a condom, and a photo; no weapons or drugs were found.
After a records check linked the ID to a burglary, A.L.T. was detained and later interviewed after waiving Miranda rights.
A.L.T. moved to suppress the victim’s driver’s license and his confession; the trial court denied the motion.
On appeal, the Fourth District held the search exceeded the scope of A.L.T.’s consent and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Mandell exceed the scope of consent?	A.L.T. contends consent to search for weapons/drugs encompassed only those items.	The search was within the scope of consent as a single search incident to questioning.	Yes; search exceeded consent.

Florida v. Jimeno, 500 U.S. 248 (1991) (consent-based searches must be objectively reasonable in scope)
Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (consent must be voluntary and considered in its totality)
Allen v. State, 909 So. 2d 435 (Fla. 5th DCA 2005) (scope of consent assessed by what a reasonable person would understand)
Aponte v. State, 855 So. 2d 148 (Fla. 5th DCA 2003) (distinguishes general search consent from targeted search for weapons/drugs)
Jean v. State, 987 So. 2d 196 (Fla. 4th DCA 2008) (deference to trial court on facts; de novo review of law)
Ikner v. State, 756 So. 2d 1118 (Fla. 1st DCA 2000) (scope and reasonableness of consent require case-by-case analysis)