State v. Williams
128 So. 3d 30
Fla. Dist. Ct. App.2012Background
- State of Florida appeals an order suppressing evidence seized after Williams’ arrest, arguing a warrantless constructive entry occurred when Williams was ordered out.
- At suppression hearing, Officer Diaz testified he observed three Black males in a backyard; one object behind a doghouse, suspected to be a firearm.
- Diaz issued a BOLO describing the three males; Rodriguez later encountered Williams after gunfire was heard in the area.
- Rodriguez approached Williams, ordered him to stop; Williams moved toward a yard, then entered the home after being confronted.
- Williams tossed a firearm into bushes; upon exiting the home he was arrested; trial court suppressed as unjustified entry.
- Court of appeal reverses, holding probable cause and hot-pursuit justification supported warrantless entry into Williams’ home.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a constructive entry into the home? | Williams | Williams | Yes, but justified under hot pursuit. |
| Does hot pursuit justify warrantless entry into the home? | Williams | State | Yes; hot pursuit exceptions apply. |
| Was there probable cause to arrest for concealed firearm? | Williams | State | Probable cause existed; arrest lawful. |
| Did the stop and entry comport with Fourth Amendment? | Williams | State | Arrest and stop permissible under hot pursuit framework. |
Key Cases Cited
- Riggs v. State, 918 So.2d 274 (Fla. 2005) (reviewing suppression rulings—fact findings deferential; questions of law de novo)
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (home entry generally prohibited absent exceptions)
- State v. Brown, 36 So.3d 770 (Fla. 3d DCA 2010) (warrantless searches/arrests in homes require established exceptions)
- Gasset v. State, 490 So.2d 97 (Fla. 3d DCA 1986) (hot pursuit justified warrantless entry in residence)
- United States v. Santana, 427 U.S. 38 (U.S. 1976) (suspect in public place may not defeat arrest by retreating to private area)
- C.E.L. v. State, 24 So.3d 1181 (Fla. 2009) (stop justified by reasonable suspicion; totality of circumstances)
- Triana, 979 So.2d 1039 (Fla. 3d DCA 2008) (coercive conduct question relevant to compelled exit)
- Ensor v. State, 403 So.2d 349 (Fla. 1981) (concealed firearm defined; visibility standards)
- Mackey v. State, 83 So.3d 942 (Fla. 3d DCA 2012) (carrying concealed firearm completed upon concealment)