State v. McCartha
The First DCA held that a single-vehicle rollover into a ditch, resulting in damage to a headlight, constitutes a 'traffic crash' under section 316.645, Florida Statutes, permitting a warrantless misdemeanor DUI arrest even though officers did not observe the defendant driving. The court reversed the trial court's suppression order, applying and extending its prior Williams decision and the Florida Supreme Court's Gaulden decision to a vehicle that flipped and came to rest upside down in a ditch.
Key facts
- State charged McCartha with DUI following a single-vehicle rollover into a ditch that caused damage to the vehicle's headlight; officers did not observe McCartha driving.
- The trial court granted McCartha's motion to suppress, finding the warrantless misdemeanor arrest violated section 901.15(1).
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Why it matters
This opinion gives law enforcement and prosecutors clear authority to treat single-vehicle rollover/ditch incidents with even minimal vehicle damage as 'crashes' justifying warrantless misdemeanor DUI arrests without… — full analysis with a trial
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