State v. Kirer, 120 So. 3d 60

Anonymous tip reported a burglary at a vacant house; appellee was seen near a vehicle in the driveway.
Deputy activated overhead lights, spotlight, siren, and PA orders to stop; deputy did not block appellee initially.
Appellee drove slowly, made multiple turns, and did not stop promptly while the deputy followed within one to two car lengths.
Two additional marked units joined; a third unit eventually blocked appellee in a townhouse community, enabling stop and identification.
Appellee was charged with fleeing or attempting to elude a law enforcement officer; appellee moved to suppress post-stop identification as the result of an unlawful stop.
Trial court granted suppression of the post-stop identification; the State appealed; the appellate court reversed, holding probable cause to stop for fleeing/eluding existed and remanding for proceedings consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was probable cause to stop for fleeing/eluding.	State: continued driving after orders created probable cause to stop.	Appellee: lack of reasonable suspicion due to initial stop being unlawful.	Probable cause existed to stop for fleeing/eluding; suppression reversed.

Henderson v. State, 88 So.3d 1060 (Fla. 1st DCA 2012) (fleeing or eluding can validate stop even when initial basis is weak; fellow-officer rule distinguished)
Ray v. State, 40 So.3d 95 (Fla. 4th DCA 2010) (emergency lights create investigatory stop; no reasonable suspicion for initial stop in some contexts)
Green v. State, 530 So.2d 480 (Fla. 5th DCA 1988) (majority held fleeing/eluding statute not contingent on lawfulness of initial stop)
Ward v. State, 59 So.3d 1220 (Fla. 4th DCA 2011) (two fleeing/eluding types; focus on lights, sirens, and defendant's defiance of orders)
United States v. Orisnord, 483 F.3d 1169 (11th Cir. 2007) (illustrates danger in vehicular fleeing situations)