Young v. State, 207 So. 3d 267

Firefighters and police responded to a small house fire at Young's residence; the garage door was open and officers/FFs entered to fight the fire and perform an administrative sweep for hazards.
While inside or while leaving through the garage, firefighters observed drug paraphernalia on a garage table and later, during a re-sweep, an open cooler of marijuana in a bedroom closet.
A fire chief escorted a police officer to the cooler; drug investigators were called and examined the cooler. Young and his girlfriend were detained and (later found to have) gave consent to search the house.
Officers did not obtain a warrant despite having time and no concern about evidence destruction; subsequent searches after detention uncovered guns and cash.
Trial court ruled the garage paraphernalia and closet marijuana were lawfully seized under the plain-view doctrine but found the post-consent search unlawful (consent involuntary) and nonetheless admitted the guns/cash under the inevitable discovery doctrine; Young pleaded no contest reserving appeal.
On appeal the court affirmed the plain-view seizures but reversed suppression denial for the guns and cash, holding inevitable discovery did not apply because police were not pursuing a warrant and consent was involuntary.

Issue	Young's Argument	State's Argument	Held
Were items seen and seized from garage/plainly visible areas admissible?	Seizures were unlawful warrantless searches.	Firefighters and officers were lawfully present during exigent/admin sweep; plain view applies.	Admissible: plain-view valid for paraphernalia and cooler marijuana.
Was marijuana in bedroom cooler lawfully observed?	Cooler was closed or not lawfully viewed; seizure invalid.	Discovered inadvertently in plain view during routine safety re-sweep by firefighters.	Admissible: plain-view during valid administrative sweep.
Were guns and cash seized after detention admissible given consent was involuntary?	Search unlawful; consent involuntary; suppress evidence.	Inevitable discovery: police could have obtained a warrant based on plain-view items.	Suppressed: inevitable discovery inapplicable because police were not pursuing a warrant and consent was involuntary.
Effect on convictions and remedy?	Entire case should be reversed or suppression required.	Some items validly admitted; convictions on cannabis/paraphernalia may stand; felon-in-possession and drug-sale charge may depend on cash.	Affirm in part (paraphernalia, marijuana convictions); reverse felon-in-possession and intent-to-sell (cash suppressed) and remand; State may retry intent-to-sell without cash.

Michigan v. Tyler, 436 U.S. 499 (establishes lawfulness of firefighter entry and administrative on-scene inspections after a fire)
Michigan v. Clifford, 464 U.S. 287 (evidence discovered during valid administrative fire inspection may be seized under plain view)
Rodriguez v. State, 187 So. 3d 841 (Fla. 2015) (inevitable discovery requires proof police were actively pursuing a warrant; rejects allowing warrantless searches absent that showing)
State v. Walker, 729 So. 2d 463 (plain-view seizure elements stated)
Hatcher v. State, 834 So. 2d 314 (defines inevitable discovery doctrine in Florida)
Cillo v. State, 849 So. 2d 353 (appellate review standard for suppression rulings)
Davis v. State, 834 So. 2d 322 (permitting summoning additional officers as part of a continuous investigative episode)
State v. Craycraft, 704 So. 2d 593 (warrantless continuation of a lawful seizure by other officers permissible where initial officers could have seized evidence)
Ensor v. State, 403 So. 2d 349 (distinguishes "open view" doctrine and when a warrant is required)
Ruilova v. State, 125 So. 3d 991 (permitting withdrawal of pleas if affected by improper suppression rulings)