Cabrera v. State
The Third District reversed the denial of a motion to suppress evidence and statements obtained after a state detective entered the defendant's fenced property based on an unproduced federal search warrant. Because neither the federal warrant nor its supporting affidavit was ever produced to the defense or the trial court, the court held there was no basis to apply the good-faith exception or the fellow-officer (collective knowledge) doctrine, and the state warrant later obtained was tainted as fruit of the initial illegal entry.
Key facts
- Detective entered defendant's fenced property based on an unproduced federal search warrant to conduct a warrantless search.
- Trial court denied defendant's motion to suppress the evidence and statements obtained from the property entry.
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Why it matters
This opinion is useful for defense counsel litigating suppression motions where law enforcement relies on an out-of-jurisdiction (especially federal) warrant that is sealed or otherwise unproduced at a state suppression… — full analysis with a trial
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