Robert Dale Purifoy v. State of Florida
225 So. 3d 867
| Fla. Dist. Ct. App. | 2017Background
- Nov. 6, 2012: Intruder wearing mask entered Justin Stanley's home; Stanley fired; Amber Johnson (houseguest) killed; Stanley wounded an intruder.
- Robert Purifoy presented at Sacred Heart Hospital shortly after with a gunshot wound; hospital staff removed his bloody clothing and placed it in a bag at the foot of his stretcher.
- A police officer observed staff removing the clothes, remained with the bag, and directed a crime scene technician to take custody; Purifoy told hospital staff and an officer he had been robbed.
- Purifoy was charged with first‑degree murder, attempted first‑degree murder, and tampering with evidence; convicted by a jury and sentenced to life on the murder and attempted murder counts and five years on tampering.
- On appeal Purifoy challenged admission of his clothing seized from the hospital (warrantless seizure), denial of access to surveillance equipment, and the sufficiency of the evidence; the court affirmed the latter two without comment and addressed the suppression claim.
Issues
| Issue | Purifoy's Argument | State's Argument | Held |
|---|---|---|---|
| Whether warrantless seizure of Purifoy's clothing at the hospital violated Fourth Amendment/Florida Constitution | Seizure was a meaningful interference with possessory rights under Jones; clothing was taken without consent or warrant | Open‑view doctrine applied because clothing in ER bay was in a public place and there was probable cause to associate it with criminal activity | The seizure was a meaningful interference, but open‑view and probable cause justified the warrantless seizure; admission affirmed |
| Whether defense was improperly denied access to surveillance equipment relied on by State | Defense argued it was denied necessary access for a fair defense | State relied on trial court rulings and preservation | Affirmed (court disposed of this issue without comment) |
| Whether evidence was insufficient as inconsistent with Purifoy's reasonable hypothesis of innocence | Purifoy argued State failed to disprove his defensive hypothesis | State argued evidence and testimony supported conviction | Affirmed (court disposed of this issue without comment) |
Key Cases Cited
- Jones v. State, 648 So. 2d 669 (Fla. 1994) (seizure of patient’s hospital clothing without warrant was meaningful interference with possessory rights; plain/open view doctrines explained)
- Buchanan v. State, 432 So. 2d 147 (Fla. 1st DCA 1983) (no reasonable expectation of privacy in curtained ER area under certain circumstances)
- Connor v. State, 803 So. 2d 598 (Fla. 2001) (standard of review for mixed questions of law and fact on suppression)
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable cause is a practical, common‑sense probability standard)
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (open‑view/plain‑view doctrines and limits on warrantless intrusions)
- Warden v. Hayden, 387 U.S. 294 (U.S. 1967) (distinguishing contraband from other property for possessory rights)
- Bernie v. State, 524 So. 2d 988 (Fla. 1988) (Florida Constitution construed in conformity with Fourth Amendment)
- Bravo v. State, 65 So. 3d 621 (Fla. 1st DCA 2011) (applying harmless‑error analysis in a Fourth Amendment context)