Warren v. State
The Fourth DCA affirmed denial of a motion to suppress a firearm found during a search incident to arrest for driving with a knowingly suspended license. The court held that probable cause to arrest for the knowing-suspension offense under section 322.34(2) can be established through circumstantial inferences—such as the type of suspension (child-support nonpayment, which triggers statutory notice procedures) and the lapse of time since suspension—without direct proof of the defendant's actual knowledge or receipt of notice.
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Key facts
- Warren was arrested for driving with a knowingly suspended license; a firearm and contraband were discovered during a search incident to arrest.
- The trial court denied Warren's motion to suppress the firearm and other evidence found during the arrest.
- +2 more key facts with a free trial
Why it matters
This opinion fills a gap in Florida law—the court noted no Florida precedent was directly on point—by articulating how officers can establish probable cause for the knowledge element of knowingly driving with a… — full analysis with a trial
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