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State v. McDuffie

Citations: 707 So. 2d 1196; 1998 Fla. App. LEXIS 3664; 1998 WL 158782Docket: No. 97-2301

Court: District Court of Appeal of Florida; April 8, 1998; Florida; State Appellate Court

Narrative Opinion Summary

The State of Florida appeals a trial court order that granted defendants Reese and McDuffie’s motion to suppress evidence obtained through a search warrant. The State concedes that Reese has standing to contest the search but disputes McDuffie's standing. The court finds that McDuffie demonstrated he had standing, referencing State v. Suco, 521 So.2d 1100 (Fla. 1988). Additionally, there were no exigent circumstances justifying the police's noncompliance with Florida's knock-and-announce statute, section 933.09, Florida Statutes (1995), citing precedents including State v. Bamber, 630 So.2d 1048 (Fla. 1994) and State v. Robinson, 565 So.2d 730 (Fla. 2d DCA, review dismissed, 574 So.2d 143 (Fla. 1990). The trial court's decision to suppress the evidence is affirmed.

Legal Issues Addressed

Affirmation of Trial Court's Suppression Order

Application: The appellate court affirmed the trial court's decision to suppress the evidence obtained through the search warrant.

Reasoning: The trial court's decision to suppress the evidence is affirmed.

Exigent Circumstances and Knock-and-Announce Requirement

Application: The court determined that there were no exigent circumstances justifying the police's noncompliance with Florida's knock-and-announce statute, leading to the suppression of the evidence.

Reasoning: Additionally, there were no exigent circumstances justifying the police's noncompliance with Florida's knock-and-announce statute, section 933.09, Florida Statutes (1995), citing precedents including State v. Bamber, 630 So.2d 1048 (Fla. 1994) and State v. Robinson, 565 So.2d 730 (Fla. 2d DCA, review dismissed, 574 So.2d 143 (Fla. 1990).

Standing to Contest Search

Application: The court found that McDuffie demonstrated he had standing to contest the search, despite the State's dispute.

Reasoning: The State concedes that Reese has standing to contest the search but disputes McDuffie's standing. The court finds that McDuffie demonstrated he had standing, referencing State v. Suco, 521 So.2d 1100 (Fla. 1988).