In Re: Amendments to the Florida Rules of Civil Procedure, Florida Small Claims Rules, and Florida Rules of Appellate Procedure – Jurisdiction

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• accepting the state's concession that retaining the passenger's identification during an otherwise valid traffic stop constituted an unjustified seizure of the passenger
• applying exploitation analysis to the determination of whether a person’s incriminating statements must be suppressed because they were the product of an unlawful detention
• giving of Miranda warnings alone was insufficient to break the causal chain where, prior to administration of warnings, unlawful police conduct had led to discovery of incriminating evidence and the defendant’s arrest, and police questioning pertained to that incriminating evidence
• relying on Rodgers /Kirkeby, the Supreme Court concluded that “the existence of a minimal factual nexus is obvious in cases in which the defendant consents to a search (or takes other incriminating action) during an illegal seizure” (emphasis in original)
• state acknowledged defendant passenger was seized when officer took and retained his identification without reasonable suspicion of criminal activity
• whether information is volunteered spontaneously, without police prompting, bears on attenuation from unlawful police conduct

Source: CourtListener parenthetical corpus (CC0).