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State v. Deferance
Citations: 807 So. 2d 806; 2002 WL 269223Docket: 4D00-4663
Court: District Court of Appeal of Florida; February 26, 2002; Florida; State Appellate Court
Maria Deferance was a passenger in a vehicle stopped for a traffic infraction and was charged with possession of cocaine after the police discovered cocaine in the car and on her person. She filed a motion to suppress the evidence and an incriminating statement made at the scene, which the trial court granted, ruling that the police lacked the right to search the vehicle after arresting the driver. The State of Florida appealed this decision. The appellate court found that the trial judge erred in concluding that the search was improper under the precedent set by *New York v. Belton*, which allows for the search of a vehicle after the driver’s arrest. Despite acknowledging this error, Deferance argued that the search was illegal for other reasons, while the State contended that the search was valid. However, the appellate court determined that the trial court did not make necessary factual findings regarding the legality of the search because it had ruled the initial search improper. The court emphasized that issues surrounding suppression can involve complex factual and legal questions and should be resolved by the trial court. It specifically noted the need for further examination of whether Deferance’s detention was lawful, if probable cause existed for her arrest based on the drugs found, whether she waived her Miranda rights, and when the actual arrest occurred. These matters were deemed mixed questions of law and fact that required additional factual findings. The appellate court reversed the trial court’s decision and remanded the case for further proceedings, allowing the trial court to either take additional testimony or make findings based on the existing record. The decision was concurred by the Chief Judge and another judge.