State v. Waiters
In a case of first impression, the Second DCA held that the 911 Good Samaritan Act's immunity provision (§ 893.21(2)) requires proximate causation, not mere 'but for' causation, between a defendant's seeking medical assistance and the discovery of contraband. Because the defendant was arrested on an outstanding warrant after EMS cleared him, and the drugs were found incident to that arrest—not as a direct result of seeking medical help—the trial court erred in dismissing the charges on immunity grounds.
Key facts
- Defendant Waiters called 911 for medical assistance and was evaluated by EMS responders.
- During or after the medical response, police discovered an outstanding arrest warrant for Waiters and arrested him; contraband was found incident to that arrest.
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Why it matters
This is the first Florida appellate decision construing the causation standard under the 911 Good Samaritan Act's immunity provision, and it forecloses an expansive 'but for' reading that could have shielded drug… — full analysis with a trial
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