State of Florida v. Christopher John Sheldon, Jr., 394 So.3d 1263

The State of Florida appealed a trial court order suppressing evidence following a traffic stop of Christopher John Sheldon, Jr.
A Florida Highway Patrol trooper stopped Sheldon’s vehicle after observing it weave several times over the fog line around 2 a.m. on Highway 19.
The trooper initiated the stop to conduct a “welfare check,” citing concerns that the driver might be ill, impaired, sleepy, or experiencing mechanical trouble.
At the suppression hearing, bodycam footage showed at least two swerves over the fog line; the trooper testified additional weaving occurred not captured on video.
The trial court found the stop improper, holding that probable cause or reasonable suspicion of a crime or infraction was required, and granted the motion to suppress.
The State argued that the stop was justified under the community caretaking doctrine.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Sheldon)	Held
Whether a traffic stop can be made for a welfare check under the community caretaking doctrine absent probable cause or reasonable suspicion of a traffic infraction or crime.	Officer may stop if specific concerns exist for driver safety, even absent traffic infraction.	Officer needed probable cause or reasonable suspicion of crime/infraction.	Court held stop was justified under caretaking doctrine.

Taylor v. State, 326 So. 3d 115 (Fla. 1st DCA 2021) (establishes community caretaking doctrine as exception to warrant requirement)
Agreda v. State, 152 So. 3d 114 (Fla. 2d DCA 2014) (stop permissible when public welfare is a concern, with less suspicion than criminal stops)
State v. Rodriguez, 904 So. 2d 594 (Fla. 5th DCA 2005) (stop justifiable absent infraction if operation raises public safety concerns)
Yanes v. State, 877 So. 2d 25 (Fla. 5th DCA 2004) (weaving can give rise to reasonable suspicion absent specific danger)