Miguel Rodriguez v. State of Florida
187 So. 3d 841
| Fla. | 2015Background
- Miguel Rodriguez seeks review of Rodriguez v. State, 129 So.3d 1135 (Fla. 3d DCA 2013), alleging conflict with this Court and other districts on inevitable discovery.
- Facts: bondsmen located a grow operation at Rodriguez’s home after client’s bond papers listed Rodriguez’s address; Rodriguez consented to a search, admitting marijuana cultivation; police called others and later obtained a warrant only after entering.
- No warrant was sought before the warrantless entry; detectives testified they would have sought one if consent hadn’t been obtained.
- Trial court denied the suppression motion but found consent coerced; it held inevitable discovery applied because probable cause existed before consent.
- Third District affirmed, holding inevitable discovery properly applied; Rodriguez argued there was no ongoing investigation and no independent pursuit of a warrant.
- This Court quashes the Third District’s decision, holding the inevitable discovery doctrine did not apply to these facts and the evidence should be suppressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether inevitable discovery requires active warrant pursuit | Rodriguez: ongoing investigation not required | State: active pursuit or ongoing investigation required | Inevitable discovery cannot apply without active pursuit |
Key Cases Cited
- Fitzpatrick v. State, 900 So.2d 495 (Fla. 2005) (establishes framework for inevitable discovery in Florida)
- Moody v. State, 842 So.2d 754 (Fla. 2003) (requires ongoing investigation and more than probable cause)
- Jeffries v. State, 797 So.2d 573 (Fla. 2001) (limits application of inevitable discovery when no ongoing investigation)
- Maulden v. State, 617 So.2d 298 (Fla. 1993) (recognizes inevitable discovery where investigation already under way)
- Nix v. Williams, 467 U.S. 431 (1984) (establishes core rationale for inevitable discovery (deterrence and fairness))
- Craig v. State, 510 So.2d 857 (Fla. 1987) (Florida precedent recognizing inevitable discovery when lawful means would have been found)