Edwards v. State
Edwards appealed the summary denial of his rule 3.850 motion challenging revocation of his probation, arguing that a later suppression order in one of the two underlying drug prosecutions (the same evidence used to revoke his probation) constituted newly discovered evidence. The Fifth District agreed that the exclusionary rule applies in probation revocation hearings and held that the timing of the suppression order—entered after the revocation hearing concluded—could constitute newly discovered evidence warranting relief under rule 3.850.
Key facts
- Edwards was on probation and faced revocation based on alleged violations stemming from two underlying drug prosecutions.
- A probation revocation hearing concluded, finding Edwards violated probation based on evidence from both drug cases; subsequently, a suppression order was entered in one prosecution excluding that evidence, while the other prosecution was nolle prossed without a suppression ruling.
- +2 more key facts with a free trial
Why it matters
This opinion clarifies that a suppression order obtained after a probation revocation hearing, addressing the same evidence that supported the revocation, can satisfy the newly discovered evidence standard for… — full analysis with a trial
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