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5th DCAOctober 2, 2026Reversed and Remanded with Instructions⭐ Notable

Holliday v. State

Case No. 5D2024-1865

Officers detained a man matching a 911 caller's generic description of a burglary suspect, despite his calm demeanor, lack of nervousness, absence of burglary tools, and the presence of two pet snakes draped around his shoulders (a detail the caller never mentioned). The Fifth DCA held that matching only innocent descriptive details from a citizen's phone tip, uncorroborated by any observed criminal conduct, did not establish the reasonable suspicion needed to justify an investigatory detention, and reversed Holliday's convictions for resisting without violence with instructions to enter a judgment of acquittal.

Key facts

  • A man was detained by officers who believed he matched a generic description of a burglary suspect provided by a 911 caller, despite the man's calm demeanor, lack of nervousness, and absence of burglary tools.
  • The detaining officers had only corroborated innocent identifying details from the 911 tip (the man's physical appearance and clothing) but had not observed any criminal conduct.
  • +2 more key facts with a free trial

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