STATE OF FLORIDA v. RAYNE BURNETT CRUME

CourtDistrict Court of Appeal of Florida
DecidedAugust 21, 2024
Docket2023-2304
StatusPublished

This text of STATE OF FLORIDA v. RAYNE BURNETT CRUME (STATE OF FLORIDA v. RAYNE BURNETT CRUME) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
STATE OF FLORIDA v. RAYNE BURNETT CRUME, (Fla. Ct. App. 2024).

Opinion

SIXTH DISTRICT COURT OF APPEAL STATE OF FLORIDA _____________________________

Case No. 6D2023-2304 Lower Tribunal No. 2022-CF-006589-O _____________________________

STATE OF FLORIDA,

Appellant,

v.

RAYNE BURNETT CRUME,

Appellee.

_____________________________

Appeal from the Circuit Court for Orange County. Robert J. Egan, Judge.

August 21, 2024

SMITH, J.

The State of Florida (“State”) appeals an order granting Appellee Rayne

Burnett Crume’s (“Crume”) motion to suppress a firearm found in his car following

a traffic stop for careless driving. The trial court ruled the State failed to establish

probable cause for the stop. We have jurisdiction. See Fla. R. App. P. 9.140(c)(1)(B).

For reasons discussed below, we reverse and remand for further proceedings.

The relevant facts are both simple and undisputed. During daytime hours on

June 8, 2022, a patrol officer was stopped at a traffic light headed westbound, with

five or six cars in front of him. Crume was traveling the same direction in the turn- only lane to the immediate left of the officer’s lane. He passed the officer’s line of

traffic until he came to a stop at the light, as the first car in the turn-only lane. After

the light turned green, Crume, rather than turn left, sped up and cut in front of the

westbound traffic.

The officer stopped Crume for careless driving, which is defined as follows:

Any person operating a vehicle upon the streets or highways within the state shall drive the same in a careful and prudent manner, having regard for the width, grade, curves, corners, traffic, and all other attendant circumstances, so as not to endanger the life, limb, or property of any person.

§ 316.1925(1), Fla. Stat. (2021). At some point after the stop, a firearm was observed

in plain view in the vehicle. Crume was arrested and charged with possession of a

firearm by a convicted felon and third-degree grand theft of a firearm.1

Crume moved to suppress the firearm and any statements made by him after

the stop,2 arguing both were fruits of an unlawful detention. At the hearing on the

motion to suppress, Crume claimed that before shifting lanes he motioned to the lead

1 The arrest affidavit indicates while the stop was on-going, the officers discovered Crume was a convicted felon and the firearm had been reported as stolen. 2 The State moved to strike Crume’s motion to suppress for failure to comply with Florida Rule of Criminal Procedure 3.190(g)(2), which requires that motions to suppress “state clearly the particular evidence sought to be suppressed, the reasons for suppression, and a general statement of the facts on which the motion is based.” The motion to strike was granted as to the statements, but not as to the firearm. Neither side has raised before this Court on appeal anything related to the statements. Based on this Court’s reversal of the order suppressing the firearm, this Court need not address the State’s argument related to the procedural sufficiency of Crume’s motion to suppress.

2 driver in front of the line of traffic headed westbound and this driver signaled to him

permission to cut in front of the line. After hearing the testimony of the officer and

Crume, the trial court granted the motion to suppress the firearm.

“The Fourth Amendment to the United States Constitution and section 12 of

Florida’s Declaration of Rights guarantee citizens the right to be free from

unreasonable searches and seizures.” Golphin v. State, 945 So. 2d 1174, 1179 (Fla.

2006); see also State v. Hickman, 363 So. 3d 217, 219 (Fla. 6th DCA 2023). A traffic

stop is a seizure. See Whren v. United States, 517 U.S. 806, 809–10 (1996); Holland

v. State, 696 So. 2d 757, 758–59 (Fla. 1997). This type of seizure is considered

reasonable, though, under the Fourth Amendment where an officer has “probable

cause to believe a traffic violation has occurred.” See Whren, 517 U.S. at 810. “The

test for probable cause is whether the [totality of the] facts and circumstances within

an officer’s knowledge are sufficient to warrant a person of reasonable caution to

believe that [it is more likely than not that] an offense has been committed.” State v.

C.J., 219 So. 3d 974, 976 (Fla. 4th DCA 2017) (alteration in original) (quoting Curtis

v. State, 748 So.2d 370, 374 (Fla. 4th DCA 2000) (en banc)); see also State v. Hebert,

8 So. 3d 393, 395 (Fla. 4th DCA 2009).

There appeared to be some confusion by the trial court as to the applicable

standard for probable cause. The court at one point stated, “the State does need to

prove he did commit a careless driving. I think that’s [the State’s] burden.” In its

written order issued after the hearing, the court similarly held, “[b]ecause there was

3 no evidence presented that the Defendant’s maneuver endangered the life, limb, or

property of another, and there was no other reason articulated for the stop, the Court

finds there was no probable cause for the subject traffic stop.” (emphasis added.) To

be fair, the court seemed to express a more accurate understanding of the probable

cause standard at other points in the hearing. The State asked for a brief recess to

research the proper standard, which was denied. At best, then, it is unclear whether

the lower court applied the proper standard in reaching its ruling.

In State v. Wimberly, 988 So. 2d 116 (Fla. 5th DCA 2008), the trial court’s

suppression order was reversed and remanded for utilizing an improper probable

cause standard. There, officers stopped a vehicle based on the belief that the

defendant’s windows were illegally tinted. The trial court granted a motion to

suppress because the unrefuted evidence showed the window tint was, in fact, legal.

Id. at 118. The Fifth District remanded the matter for the trial court to utilize the

proper standard: “It appears to us that the trial court concluded that because the

window tint was legal, the traffic stop was illegal, requiring suppression of the drugs

and statements. That is not the standard to be used by the court.” Id. at 120. As in

Wimberly, the court below appears to have erred in focusing on whether a traffic

violation occurred rather than the correct standard: whether, viewed under an

objective lens, the “totality of the facts known to the officer at the time would cause

a reasonable person to believe that an offense has been committed.” Hebert, 8 So.

3d at 395.

4 Having clarified the proper standard to apply for probable cause, we move on

to discuss its application. A trial court’s ruling on a motion to suppress is a mixed

question of fact and law, and “[w]e defer to the trial court’s findings of fact, if they

are supported by competent, substantial evidence,” but “review de novo mixed

questions of law and fact and the trial court’s legal conclusions.” Hickman, 363 So.

3d at 219. The ruling on a motion to suppress comes to us clothed with a presumption

of correctness, and we must interpret the evidence and reasonable inferences from it

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Related

Whren v. United States
517 U.S. 806 (Supreme Court, 1996)
State v. Hebert
8 So. 3d 393 (District Court of Appeal of Florida, 2009)
State v. Furr
723 So. 2d 842 (District Court of Appeal of Florida, 1998)
Holland v. State
696 So. 2d 757 (Supreme Court of Florida, 1997)
Everett v. State
893 So. 2d 1278 (Supreme Court of Florida, 2004)
State v. Wimberly
988 So. 2d 116 (District Court of Appeal of Florida, 2008)
Golphin v. State
945 So. 2d 1174 (Supreme Court of Florida, 2006)
Curtis v. State
748 So. 2d 370 (District Court of Appeal of Florida, 2000)
State v. C.J.
219 So. 3d 974 (District Court of Appeal of Florida, 2017)

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STATE OF FLORIDA v. RAYNE BURNETT CRUME, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-florida-v-rayne-burnett-crume-fladistctapp-2024.