State v. Page, 73 So. 3d 351

Two Fort Lauderdale officers on 1:00 a.m. patrol observed appellee near a 24-hour market in a narcotics-crime hotspot.
The officer approached on foot without activating lights or drawing weapons; appellee was free to leave per testimony.
The officer asked for appellee’s name and date of birth; appellee complied, and the information was run for active warrants.
A valid active warrant was found, leading to appellee’s arrest for the warrant and Miranda rights were administered.
A subsequent search yielded approximately fifteen grams of marijuana in appellee’s pocket; appellee later gave a spontaneous statement about the marijuana.
At the suppression hearing, the trial court found the encounter initially consensual but concluded the warrants check transformed it into an unlawful stop, prompting suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does a warrants check based on name/DOB convert a consensual contact into a seizure?	Appellee and Golphin guidance show no Fourth Amendment seizure merely from a warrants check.	The warrants check before detecting the warrant created a detention requiring reasonable suspicion.	Warrants check did not require reasonable suspicion; the encounter remained permissible.
Was Golphin misapplied as controlling in this case?	Golphin supports noncompulsory ID requests not implicating Fourth Amendment rights.	Golphin supports suppressing where a warrant is checked during a consensual encounter.	Golphin was misinterpreted; warrants check did not mandate suppression.
Should the trial court’s suppression order be affirmed or reversed and remanded for factual findings?	Trial court erred in requiring reasonable suspicion solely for a warrants check.	The evidence and testimony support suppression due to lack of reasonable suspicion.	Reversed and remanded for factual findings on consensual vs illegal stop and related factors.

O.A. v. State, 754 So.2d 717 (Fla. 4th DCA 1998) (noncompulsory identification requests rarely implicate the Fourth Amendment)
State v. Goodwin, 36 So.3d 925 (Fla. 4th DCA 2010) (mere questioning/identification requests do not amount to detention)
Golphin v. State, 945 So.2d 1174 (Fla.2006) (identification used for warrants check does not automatically implicate Fourth Amendment; non-driver context)
San Martin v. State, 717 So.2d 462 (Fla.1998) (appellate review of trial court findings; efficiency of factual review)
Frierson, 926 So.2d 1139 (Fla.2006) (factors for excluding evidence after illegal stop: time, intervening circumstances, misconduct purpose/flagraney)
Popple v. State, 626 So.2d 185 (Fla.1993) (three levels of police-citizen encounters; consensual to detained to arrest)
State v. Woodard, 681 So.2d 733 (Fla. 2d DCA 1996) (warrants check per se does not convert encounter into seizure)
Caldwell v. State, 41 So.3d 188 (Fla.2010) (framework for mixed questions of law and fact in appellate review)