May v. State, 2012 Fla. App. LEXIS 179

May pled no contest to two counts of filing false information about prescriptions and a probation violation, reserving appeal on suppression denial.
Detective surveilled a pain clinic under DEA scrutiny; May and a co-defendant exited clinic and entered a vehicle.
Vehicle left; detective followed and observed a prescription bottle being passed from front to rear seats with May present.
Traffic stop for a brake-light violation occurred, though the brake-light issue was admitted to be legally insufficient for a ticket.
Suppression motion denied after detective testified to patterns of pill sharing and cash-only clinics; credibility found.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by reasonable suspicion	May argues no reasonable suspicion existed.	State contends observations and training supported suspicion.	Yes, based on totality of circumstances.
Whether drug-sharing patterns near pain clinics support suspicion	Benemerito-like reliance shows lack of concrete observation of drugs.	Detective's experience renders bottle transfer suspicious.	Yes, sufficient under totality of circumstances.
Whether observation of passing an amber prescription bottle suffices for stop	Passing bottle alone cannot show drugs or money moved.	Circumstances show suspicious transfer of pills.	Yes, bottle transfer enough under context.

Benemerito v. State, 29 So.3d 367 (Fla. 4th DCA 2010) (observational basis for reasonable suspicion limited when no drugs seen)
Santiago v. State, 941 So.2d 1277 (Fla. 4th DCA 2006) (observing drug transfer not necessary; other factors may establish suspicion)
Davis v. State, 849 So.2d 398 (Fla. 4th DCA 2003) (founded/specific reasonable suspicion standard)
Popple v. State, 626 So.2d 185 (Fla.1993) (investigatory stop requires well-founded suspicion)
Origi v. State, 912 So.2d 69 (Fla. 4th DCA 2005) (equated founded with reasonable suspicion)