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125 So. 3d 271
Fla. Dist. Ct. App.
2013
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Background

  • Defendant convicted of robbery with a deadly weapon and aggravated battery after an incident where he demanded money from the victim, a struggle occurred, and the victim was injured.
  • Two days later, an officer saw the defendant’s car missing a side-view mirror and stopped him for driving with a suspended license; the officer arrested him.
  • A search incident to arrest yielded a blank check with the victim’s name and two pocket knives in the defendant’s pockets, plus possible blood stains on the car trunk.
  • At suppression, the State argued the stop was justified by safety equipment statutes; the trial court denied the suppression motion, finding the missing mirror made the vehicle unsafe.
  • The appellate court reversed, holding the stop illegal because the absence of a single exterior mirror did not establish unsafe condition under the statute and because the State failed to prove the vehicle was unsafe, and remanded for a new trial; the court also left undecided the voir dire issue but found merit in the suppression issue.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Validity of traffic stop based on missing mirror Defendant argues stop valid under safety statutes State relied on safety statutes but did not prove unsafe vehicle Stop illegal; suppression granted

Key Cases Cited

  • Hilton v. State, 961 So.2d 284 (Fla. 2007) (statutory interpretation; stop permissible only if vehicle unsafe; burden on State)
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Case Details

Case Name: Springer v. State
Court Name: District Court of Appeal of Florida
Date Published: Mar 6, 2013
Citations: 125 So. 3d 271; 38 Fla. L. Weekly Fed. D 547; 2013 Fla. App. LEXIS 3519; 2013 WL 811673; No. 4D10-3232
Docket Number: No. 4D10-3232
Court Abbreviation: Fla. Dist. Ct. App.
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