Castillo v. State
The Third DCA affirmed a DUI conviction, holding that a warrantless misdemeanor arrest was lawful under the 'fellow officer rule' even though neither officer directly witnessed the defendant driving. The court held that the defendant's oral admission to the first officer that he had driven to the scene was constructively equivalent to that element occurring in the officer's presence, allowing the two officers' combined observations to establish probable cause for arrest.
Key facts
- Defendant was arrested for DUI without a warrant based on two officers' combined observations: one officer obtained defendant's oral admission that he had driven to the scene, and the other officer observed signs of impairment.
- The trial court denied defendant's motion to suppress the arrest, and defendant was convicted of DUI.
- +2 more key facts with a free trial
Why it matters
This opinion is useful to DUI practitioners because it extends the fellow officer rule to allow an officer's contemporaneous relay of a suspect's admission (rather than direct observation) to satisfy the 'driving'… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.