Majors v. State
70 So. 3d 655
Fla. Dist. Ct. App.2011Background
- Bank 911 call described a customer acting oddly while attempting a large withdrawal and interacting with occupants of a Nissan parked nearby.
- Officers arrived, observed a Nissan matching the description, and blocked its exit to approach the vehicle with Majors inside.
- Majors was arrested and evidence was seized after the stop, which the defense moved to suppress as lacking reasonable suspicion.
- Trial court denied suppression; Majors pled nolo contendere to several counts, reserving appeal of the suppression ruling.
- Issues on appeal concern whether the Nissan stop was supported by reasonable suspicion or by the community caretaking doctrine.
- Appellate court reviews suppression rulings de novo for legal conclusions and with competent substantial evidence for factual findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion to stop the Nissan? | Majors argues no reasonable suspicion existed. | State contends the stop was justified by collective knowledge and circumstances. | No reasonable suspicion existed; stop violated Fourth Amendment. |
| Does community caretaking justify the stop? | Majors asserts caretaking not applicable. | State urges caretaking as permissible without criminal suspicion. | Caretaking not supported by articulable public-safety facts; rejected. |
Key Cases Cited
- Popple v. State, 626 So.2d 185 (Fla. 1993) (establishes levels of police-citizen encounters and need for reasonable suspicion)
- Dees v. State, 564 So.2d 1166 (Fla. 1st DCA 1990) (investigatory detention defined by official show of authority)
- Faunce v. State, 884 So.2d 504 (Fla. 1st DCA 2004) (reasonable suspicion must be articulable and well-founded)
- Hill v. State, 51 So.3d 649 (Fla. 1st DCA 2011) (empty of specific criminal activity does not establish reasonable suspicion)
- Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (flight can be a factor but not alone to establish suspicion)
- U.S. v. Martinez-Fuerte, 428 U.S. 543 (U.S. 1976) (warrantless seizures require alignment with Fourth Amendment norms)
- Cady v. Dombrowski, 413 U.S. 433 (U.S. 1973) (community caretaking concept discussed with limitations)
- State v. Maynard, 783 So.2d 226 (Fla. 2001) (fellow-officer rule for information sharing in evaluating stops)
- McKnight v. State, 972 So.2d 247 (Fla. 1st DCA 2007) (supports de novo review of suppression rulings)
- Wardlow and related discussion (Hill citation), Hill v. State, 51 So.3d 649 (Fla. 1st DCA 2011) (illustrates limitations of flight as sole basis for suspicion)
- U.S. v. Wardlow, 528 U.S. 119 (U.S. 2000) (flight from police is a factor, not sole basis)