State v. Wilson
State v. Wilson
Opinion of the Court
Following a traffic stop, Dion Renoldo Wilson was arrested and charged with trafficking in a controlled substance and possession of cannabis with intent to sell. Wilson filed a motion to suppress, arguing that law enforcement had no probable cause to conduct a traffic stop for failure to maintain a single lane. In an unelaborated order, the trial court granted the motion and the State now appeals. We reverse.
Deputy Sheriff Jeffrey Payne was the only witness at the suppression hearing. Deputy Payne testified that he was driving westbound on Americana Boulevard, a four-lane highway. He observed a silver SUV about two car lengths ahead of him, also traveling westbound on Americana. The silver SUV then "drifted over the dotted lane divider causing a vehicle to the right of us to ... have to brake" to avoid a collision. Deputy Payne ultimately stopped the silver SUV, which Wilson was driving. Wilson only challenged the probable cause for the traffic stop at the suppression hearing.
When reviewing a suppression order, we give deference to the trial court's historical facts so long as they are supported by competent, substantial evidence, but we review de novo the trial court's application of law to those facts. Patrick v. State,
The statute, relating to the operation of a vehicle within a single lane, mandates, in pertinent part, that "[a] vehicle shall be driven as nearly as practicable entirely within a single lane and shall not be moved from such lane until the driver has first ascertained that such movement can be made with safety." § 316.089(1), Fla. Stat. (2018) (emphasis added). The failure to maintain a single lane alone cannot establish probable cause when the action is done safely. See Jordan v. State,
For these reasons, we reverse the suppression order and remand this case for further proceedings consistent with this opinion.
REVERSED and REMANDED.
LAMBERT and SASSO, JJ., concur.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.