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Keywords

precedentappealmotionprobation

appealwillprobation

Related Cases

Presley v. State, 227 So.3d 95, 42 Fla. L. Weekly S817

Facts

Gregory Presley was on drug offender probation with a condition to abstain from alcohol and illegal drugs. During a traffic stop for a faulty taillight, officers detained Presley and another passenger while dealing with a struggle involving the driver. Presley provided his identification and admitted to consuming alcohol, leading to his arrest for violating probation. A search incident to his arrest revealed cocaine in his pocket. Presley moved to suppress the evidence, claiming illegal detention, but the circuit court denied the motion.

At the time of the events in this case, Gregory Presley was on drug offender probation. A special condition of the probation provided, 'You will abstain entirely from the use of alcohol and/or illegal drugs, and you will not associate with anyone who is illegally using drugs or consuming alcohol.' During the early morning hours of January 29, 2015, Gainesville police officer Tarik Jallad conducted a traffic stop of a vehicle for a faulty taillight and a stop sign violation. Presley was one of two passengers in the vehicle.

Issue

Whether law enforcement officers may, during a lawful traffic stop, detain a passenger as a matter of course for the duration of the stop without violating the passenger's Fourth Amendment rights.

The holdings in Presley and Wilson v. State reach opposite conclusions on a legal issue—whether law enforcement officers may, during a lawful traffic stop, detain a passenger as a matter of course for the duration of the stop without violating the passenger's Fourth Amendment rights.

Rule

Law enforcement officers may detain passengers for the reasonable duration of a traffic stop without violating the Fourth Amendment, as established by precedent in cases such as Pennsylvania v. Mimms and Maryland v. Wilson.

The First District recognized that in Pennsylvania v. Mimms, 434 U.S. 106, 98 S.Ct. 330, 54 L.Ed.2d 331 (1977), and Maryland v. Wilson, 519 U.S. 408, 117 S.Ct. 882, 137 L.Ed.2d 41 (1997), the United States Supreme Court held that both drivers and passengers can be asked to exit the vehicle during a traffic stop.

Analysis

The court applied the rule by examining the circumstances of the traffic stop and the nature of the detention. It concluded that the limited duration of the detention did not significantly interfere with Presley's Fourth Amendment rights. The court emphasized the importance of officer safety and the need for officers to maintain control during traffic stops, which justified the detention of passengers.

The First District noted that the Aguiar court concluded the analysis in Wilson v. State was flawed because it failed to give sufficient deference to officer safety.

Conclusion

The court affirmed the decision of the District Court of Appeal, holding that the detention of Presley during the traffic stop was lawful and did not violate his Fourth Amendment rights.

The Supreme Court then concluded that the intrusion upon the liberty interest of the driver was de minimis.

Who won?

The State prevailed in the case, as the court upheld the lawfulness of the detention and the subsequent evidence obtained during the arrest.

The First District Court of Appeal affirmed, holding that 'an officer may, as a matter of course, detain a passenger during a lawful traffic stop without violating the passenger's Fourth Amendment rights.'

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