State v. Scott B. Hayward
215 So. 3d 178
| Fla. Dist. Ct. App. | 2017Background
- Detective Kuzma swore an affidavit after a confidential source conducted a controlled purchase: the source bought ~4 ounces (113 g) of cocaine from Hayward for $4,800 at a designated IHOP meeting.
- Hayward was under surveillance when he received the call; he drove to his residence, stayed ~15 minutes, then drove directly to the IHOP and delivered the drugs.
- During arrest Hayward discarded a bag with suspected cocaine (field test positive). A vehicle search uncovered additional cocaine (46.9 g), methamphetamine (16.5 g), scale, and packaging materials.
- The same day a search warrant for Hayward’s residence was executed, producing ~274 g of cocaine.
- Hayward moved to suppress the residential evidence, arguing the affidavit lacked a nexus showing probable cause to search his home; the trial court granted suppression. The State appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the affidavit established probable cause to search Hayward’s residence | Affidavit lacked facts connecting the delivery and seized items to Hayward’s home; no nexus shown | Surveillance plus short stop at home between call and delivery, substantial quantity and packaging items provide a reasonable nexus | Probable cause existed: circumstantial inferences (stop at home, quantity, packaging) created a sufficient nexus |
| Whether the good-faith exception applies if affidavit insufficient | Good-faith exception inapplicable because affidavit was “so lacking” that reliance on warrant was unreasonable | Even if affidavit defective, officer reasonably relied on the warrant; exception applies | Good-faith exception would apply; evidence admissible under objectively reasonable reliance |
Key Cases Cited
- State v. Weil, 877 So. 2d 803 (Fla. 5th DCA 2004) (residence may be searched when instrumentalities of offense reasonably inferred to be stored there)
- State v. McGill, 125 So. 3d 343 (Fla. 5th DCA 2013) (discussing good-faith exception under Leon)
- United States v. Leon, 468 U.S. 897 (1984) (establishing good-faith exception to exclusionary rule)