State of Florida v. Clarence E. Johnson, 208 So. 3d 843

Officers arrived at Johnson's home to execute an arrest warrant; Johnson returned as they were leaving and was told of the warrant.
Johnson, with a child sleeping in the car, asked officers to arrest him out of the child’s view; officers handcuffed and searched him beside his car.
Officers found $1,188 in cash in Johnson’s pocket, placed it on the trunk, then dumped it onto the driver’s seat through the open driver door to prevent it from blowing away.
A friend arrived to care for the child and property; Johnson elected to have the friend take the cash rather than have it inventoried at jail.
An officer reached into the open driver door to retrieve the cash for safekeeping and observed a baggie of white powder on the driver’s seat; the officer seized it and Johnson was charged with possession.
Trial court suppressed the evidence as an illegal warrantless search; the State appealed arguing the intrusion was a caretaking/property-protection act and, alternatively, that suppression should not apply.

Issue	State's Argument	Johnson's Argument	Held
Whether officer’s reach into vehicle to retrieve owner’s cash was a warrantless search violating the Fourth Amendment	The reach was a community-caretaking/property-protection act to secure the owner’s property; no warrant or probable cause required	The intrusion into the car required a warrant or probable cause and thus was an illegal search/seizure	The reach was reasonable caretaking; no Fourth Amendment violation
Whether cocaine observed and seized during that reach was admissible under plain view	Once officer had a right to be in position (reaching to secure cash), items in plain view could be seized	The baggie was not in plain view when cash was placed and thus seizure was unlawful	The baggie was visible to the officer while reaching for the cash; seizure lawful

Cady v. Dombrowski, 413 U.S. 433 (search to protect public safety from unsecured weapon upheld as reasonable)
Harris v. United States, 390 U.S. 234 (items discovered while securing impounded vehicle not subject to Fourth Amendment suppression)
Cooper v. California, 386 U.S. 58 (vehicle safety/ custodial measures can justify intrusion)
State v. Oglesby, 397 So. 2d 714 (Fla. 1st DCA 1981) (taking property into custody for safekeeping not constitutionally unreasonable)
Cobb v. State, 378 So. 2d 82 (Fla. 3d DCA 1979) (opening door to secure vehicle was not a search for evidence)
State v. Baez, 894 So. 2d 115 (Fla. 2004) (totality of circumstances governs Fourth Amendment analysis)
State v. Cash, 275 So. 2d 605 (Fla. 1st DCA 1973) (plain-view doctrine allows seizure when officer properly positioned)
Arizona v. Gant, 556 U.S. 332 (search-incident-to-arrest limits recognized but other exceptions may apply)
Brigham City v. Stuart, 547 U.S. 398 (officer’s subjective motivation irrelevant; objective circumstances control)
Scott v. United States, 436 U.S. 128 (Fourth Amendment reasonableness judged objectively)
Vaughn v. State, 176 So. 3d 354 (Fla. 1st DCA 2015) (appellate review accepts fact findings supported by competent substantial evidence)