Vaughn v. State
176 So. 3d 354
| Fla. Dist. Ct. App. | 2015Background
- Early morning August 14, 2013: Gainesville PD Officer Futrell stopped Vaughn for allegedly illegal window tint and a television visible on the dashboard.
- Officer requested license, registration, and home address; Vaughn gave three different addresses (license, registration, orally).
- Officer asked if Vaughn had weapons; Vaughn admitted to carrying a knife. Additional officers and a K-9 arrived; Officer asked Vaughn to exit the vehicle for safety.
- A pat-down recovered a box-cutter/utility knife; white powdery residue on the knife tested positive for cocaine in a field test.
- Probable cause to arrest followed; a search incident to arrest produced additional narcotics on Vaughn.
- Lower court denied Vaughn’s motion to suppress; this appeal challenges that denial.
Issues
| Issue | Appellant's Argument | State's Argument | Held |
|---|---|---|---|
| Whether the traffic stop and subsequent detention exceeded the stop’s scope / lacked reasonable suspicion | Stop progressed into unlawful investigative detention without reasonable suspicion | Initial stop lawful (tint/TV); inconsistent addresses gave reasonable suspicion to investigate registration/address | Affirmed: stop lawful; detention supported by reasonable suspicion |
| Whether asking Vaughn to exit the vehicle and frisking him was lawful | Officer had no reasonable suspicion or safety basis to order exit/frisk (cites Gilchrist) | Vaughn admitted to having a knife; officer reasonably concerned for safety and could remove/search for weapon | Affirmed: officer reasonably believed Vaughn was armed; removal and frisk lawful |
| Whether seizure of the knife and observation of residue produced valid probable cause | Seizure/observation unlawful, so residue should be suppressed | Residue in plain view on a lawfully seized knife supported probable cause | Affirmed: visible residue on lawfully seized knife supplied probable cause to arrest |
| Whether evidence (cocaine on person) should be suppressed as fruit of unlawful detention/search | Narcotics were fruit of unconstitutional actions and must be suppressed | Once probable cause and lawful arrest existed, search incident to arrest lawfully uncovered additional narcotics | Affirmed: search incident to arrest valid; narcotics admissible |
Key Cases Cited
- Higerd v. State, 54 So.3d 513 (Fla. 1st DCA 2010) (standard for reviewing suppression rulings involves mixed fact-law review)
- Butler v. State, 706 So.2d 100 (Fla. 1st DCA 1998) (trial court’s factual findings reviewed for competent, substantial evidence; legal application reviewed de novo)
- Murray v. State, 692 So.2d 157 (Fla. 1997) (trial court suppression rulings entitled to presumption of correctness; inferences construed to sustain ruling)
- State v. Moore, 791 So.2d 1246 (Fla. 1st DCA 2001) (officer’s observation of dark tinted windows justified stop)
- Gilchrist v. State, 757 So.2d 582 (Fla. 1st DCA 2000) (officer’s request to exit post-ticket without reasonable suspicion or safety concern was unlawful and required suppression)