State v. L.C.
In a juvenile delinquency case, the Second DCA reversed a trial court order suppressing an investigatory stop and show-up identification of L.C., a suspect in an attempted burglary. The court held that a citizen informant's BOLO describing four black males in shorts, some shirtless, was sufficiently specific to justify a Terry stop even though L.C. was mixed-race and wore a shirt, given the short time elapsed, proximity to the crime scene, and officer testimony explaining discrepancies. The court also held the show-up procedure was not unnecessarily suggestive, reaffirming that presenting a suspect in handcuffs does not itself render an identification procedure unduly suggestive.
Key facts
- L.C., a juvenile, was arrested following an attempted burglary and identified through a show-up procedure conducted by police after an investigatory stop.
- A citizen informant provided a BOLO describing four black males in shorts, some shirtless; L.C. was mixed-race and wore a shirt when stopped shortly after the crime near the scene.
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Why it matters
This opinion provides a useful, fact-rich application of the BOLO reasonable-suspicion factors from Hunter and M.M., particularly addressing how officers may reasonably attribute discrepancies in race or clothing… — full analysis with a trial
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