Littles v. State
The Fifth DCA reversed the denial of a motion to suppress drugs found after a traffic stop, holding that an officer's mistaken belief that the defendant had illegally switched from a left-turn lane to a thru lane was not objectively reasonable given the intersection's clear, unambiguous lane markings and signals. The court applied a less-deferential standard of review to the trial court's findings because they were based on dashcam video evidence, and concluded the stop was unlawful from the outset.
Key facts
- Littles was charged with drug possession after officers discovered drugs during a traffic stop; the trial court denied his motion to suppress the drugs.
- An officer stopped Littles's vehicle based on a claimed belief that Littles illegally switched from a left-turn lane to a thru lane at an intersection.
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Why it matters
This case is useful for defense practitioners litigating motions to suppress based on an officer's claimed mistake of fact justifying a traffic stop, particularly where the mistake involves lane position or signage that… — full analysis with a trial
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