MM v. State, 80 So. 3d 1125

Sgt. Anton was dispatched to a high-crime area for an armed robbery, with a BOLO stating two white males robbed a victim at gunpoint and fled on foot.
The sergeant never spoke to the purported robbery victim nor received information from the victim.
At about 12:30 a.m., the sergeant encountered appellant and another man roughly three blocks from the robbery area, within minutes of the dispatch.
The sergeant detained the two individuals, uncertain whether they were involved in any crime, and ordered them to place their hands on the hood of his car.
Another officer patted down appellant, felt a bulge in his right pocket, asked appellant to remove it, and found a bag of marijuana.
Appellant moved to suppress the marijuana; the trial court denied; appellant pleaded no contest reserving appellate rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the BOLO provided reasonable suspicion to stop M.M.	M.M. contends the BOLO description was too vague to justify a stop.	State contends proximity to the crime and time of day support a reasonable suspicion.	No reasonable suspicion; reversal of denial of suppression.

Popple v. State, 626 So. 2d 185 (Fla.1993) (reasonable suspicion required for investigatory stops)
Jean v. State, 987 So. 2d 196 (Fla. 4th DCA 2008) (focus on contemporaneous suspicious behavior near crime scene)
Pantin v. State, 872 So. 2d 1000 (Fla. 4th DCA 2004) (bare-bones BOLO description insufficient for stop)
Sapp v. State, 763 So. 2d 1257 (Fla. 4th DCA 2000) (BOLO for specific demographics near address insufficient)
L.T.S. v. State, 391 So. 2d 695 (Fla. 1st DCA 1980) (lack of specificity undermines reasonable suspicion)
Taylor v. State, 695 So. 2d 503 (Fla. 2d DCA 1997) (generic or vague descriptions do not justify stops)
Rigterink v. State, 66 So. 3d 866 (Fla.2011) (standards for reviewing suppression rulings de novo)
Fuentes v. State, 24 So. 3d 1231 (Fla.4th DCA 2009) (application of law to historical facts in suppression)