State of Florida v. Kerrick Van Teamer
151 So. 3d 421
Fla.2014Background
- Deputy observed Teamer driving a green car and later the same car; plate color did not match registration color.
- Based on color discrepancy, deputy stopped the vehicle for an investigatory purpose without observed illegal activity.
- During the stop, deputy detected a strong odor of marijuana and searched Teamer and the vehicle.
- Teamer was charged with trafficking cocaine, possession of marijuana, and paraphernalia; motion to suppress denied by trial court.
- First District reversed, finding color discrepancy alone does not justify an investigatory stop; conflict with Aders, and ordered Teamer discharged.
- State argues good faith reliance on Aders; majority rejects good faith exception as Aders issued after the stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is a color registration discrepancy alone reasonable suspicion? | Teamer | Teamer | Color discrepancy alone not reasonable suspicion |
| May a single noncriminal factor justify a stop under Terry? | Teamer | Teamer | No; requires more than one factor or articulable suspicion |
| Was the stop reasonable under the totality of the circumstances? | Teamer | Teamer | Not reasonable; balance weighs in motorist's favor |
| Do good-faith reliance or binding precedent justify admission of evidence? | Teamer | Teamer | No to good-faith exception; Aders not binding at time of stop |
| Should the exclusionary rule apply to suppress evidence here? | Teamer | Teamer | Exclusionary rule applies; evidence suppressed |
Key Cases Cited
- United States v. Sokolow, 490 U.S. 1 (U.S. 1989) (reasonableness and reasonable suspicion standard)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes stop with reasonable suspicion)
- Popple v. State, 626 So.2d 185 (Fla. 1993) (reasonable suspicion required for investigatory stop)
- United States v. Cortez, 449 U.S. 411 (U.S. 1981) (totality of the circumstances standard)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (objective standard for reasonable suspicion)
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (totality of the circumstances analysis as applied to reasonable suspicion)
- Brignoni-Ponce, 422 U.S. 873 (U.S. 1975) (single factor (appearance) not enough for suspicion)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (random vehicle stops; necessity of reasonable checks)
- Place v. United States, 462 U.S. 696 (U.S. 1983) (balancing intrusion vs. government interest)
- Mimms v. United States, 434 U.S. 106 (U.S. 1977) (balancing interests in reasonableness)
- Diaz v. State, 850 So.2d 435 (Fla. 2003) (reasonableness balancing on motorist rights)
- Hilton v. State, 961 So.2d 284 (Fla. 2007) (exclusionary rule deterrence)