State of Florida v. Rayshard Brinson
6D2024-0122
Fla. Dist. Ct. App.Mar 21, 2025Background
- Law enforcement responded to a reported domestic violence dispute at Rayshard Brinson’s home in 2020, but evidence collected exonerated Brinson from that incident.
- During the domestic investigation, police found Brinson had an outstanding arrest warrant for drug trafficking, and he was arrested.
- While in jail, Brinson made incriminating phone calls discussing the movement of "construction materials" (interpreted as drugs), which law enforcement monitored.
- Using information from those calls, police obtained a search warrant (omitting exculpatory statements about domestic violence), executed a search of Brinson’s home, and uncovered further evidence.
- The trial court suppressed evidence from the search warrant due to the omission of exonerating information, and dismissed all charges as fruit of the poisonous tree; the State appealed the dismissal of some charges.
Issues
| Issue | State's Argument | Brinson's Argument | Held |
|---|---|---|---|
| Suppression of All Evidence | Not all evidence stems from tainted search warrant; evidence from jail calls/co-defendant’s car valid | All evidence implicating Brinson is fruit of the unlawful warrant | Only warrant-derived evidence suppressed; charges based on other evidence reinstated |
| Application of Fruit of the Poisonous Tree Doctrine | Jail calls and vehicle search predate and are independent from warrant; should not be suppressed | All prosecution evidence is derivative and must be suppressed | Doctrine only applies to evidence actually derived from illegality |
| Sufficiency of Remaining Evidence | Jail calls and seized narcotics suffice to proceed to trial | Without suppressed evidence, insufficient grounds for charges | Remaining evidence adequate to proceed to trial on certain counts |
| Scope of Dismissal | Dismissal of all counts improper; some counts still supported by admissible evidence | All charges dismissible due to state’s misconduct in warrant affidavit | Dismissal reversed for counts based on unsuppressed evidence |
Key Cases Cited
- Utah v. Strieff, 579 U.S. 232 (2016) (discussing ambits of exclusionary rule and causal connection between illegality and discovery)
- Segura v. United States, 468 U.S. 796 (1984) (distinguishes primary evidence from derivative evidence for exclusionary rule)
- Craig v. State, 510 So. 2d 857 (Fla. 1987) (explains fruit of poisonous tree, requiring link to illegal act)
- Hatcher v. State, 834 So. 2d 314 (Fla. 5th DCA 2003) (defining the fruit of the poisonous tree doctrine)