Wilson v. State

16 Citing cases

  1. United States v. Hines

    717 F.2d 1481 (4th Cir. 1983)   Cited 68 times
    Affirming the decision of the district court to allow the defendant to read only relevant grand jury testimony to the jury

    Appellants challenge the electronic surveillance on the grounds that it was issued based on an affidavit that contained intentional, reckless, and material misrepresentations. Appellants contend that Maxwell and Dorn, Jacksonville Beach police officers, acted outside their jurisdiction by consensually monitoring Bones's nine pre-August 6, 1981 calls to Jacques's St. Johns County home. Maxwell and Dorn were not deputized in St. Johns County until August 6, 1981. Appellants rely on Wilson v. Florida, 403 So.2d 982 (Fla. 1980), in which Lake City, Florida, police officers conducted an investigation into Wilson's possession of drugs outside the municipal limits of Lake City. In conducting the investigation, the officers employed an electronic listening device that was hidden on an informant who purchased drugs from Wilson outside Lake City. The court held that fruits of the electronic surveillance could not form the basis for the issuance of a search warrant because the officers were without authority to conduct the investigation.

  2. State v. Kessler

    19-cv-00468-MW-HTC (N.D. Fla. Feb. 23, 2022)

    Inv. Huston was wearing his TPD badge and TPD letterhead on all of his documentation to include the document used when the Defendant waived his Miranda Rights. Agent Chad Hoffman did not generate any reports nor did he have any knowledge of this specific case. DCA 2003); Wilson V. State 403 So.2d 982 (Fla 1 After the TPD interrogation, AFOSI Agents Sara Winchester and Shane Nishioka questioned the Defendant.

  3. Kessler v. Sec'y of the Fla. Dep't of Corrs.

    4:19cv468-MW-HTC (N.D. Fla. Feb. 23, 2022)   Cited 2 times

    Such investigations are, however, limited to those situations where the subject matter of the investigation originated inside the city limits.” Wilson v. State, 403 So.2d 982, 984 (Fla. 1st DCA 1980) (citing State v. Chapman, 376 So.2d 262 (Fla. 3d DCA 1979)).

  4. State v. Cody

    248 Neb. 683 (Neb. 1995)   Cited 42 times

    In support of this theory, Cody cites a variety of cases from various jurisdictions. E.g., Phipps v. State, 841 P.2d 591 (Okla. Crim. App. 1992); Wilson v. State, 403 So.2d 982 (Fla. App. 1980); People v. Martin, 225 Cal.App.2d 91, 36 Cal.Rptr. 924 (1964). Even assuming arguendo that Cody's theory is sound, a matter we do not decide, this case does not fit the fact pattern found in the cited cases.

  5. State v. Repple

    No. 6D23-1448 (Fla. Dist. Ct. App. Jun. 14, 2024)

    The fact that the officers later learned that the acts of abuse only occurred in Margate, outside their jurisdiction, did not invalidate the authority they had to record a controlled call within their jurisdiction in order to investigate a crime they had reason to believe occurred within their jurisdiction. The Knight court also cited State v. Allen, 790 So.2d 1122, 1125 (Fla. 2d DCA 2001), and Wilson v. State, 403 So.2d 982, 984 (Fla. 1st DCA 1980). Price is a two-paragraph opinion.

  6. State v. Stouffer

    248 So. 3d 1165 (Fla. Dist. Ct. App. 2018)   Cited 2 times   1 Legal Analyses

    852 So.2d at 391–93. This case is also unlike Wilson v. State , 403 So.2d 982 (Fla. 1st DCA 1980), and State v. Allen , 790 So.2d 1122 (Fla. 2d DCA 2001), which appellees rely upon on appeal, because in each of those cases the investigation originated outside the officer's jurisdiction.In conclusion, the plain language of the statutes governs our analysis.

  7. Knight v. State

    154 So. 3d 1157 (Fla. Dist. Ct. App. 2015)

    One exception allows an officer to act outside of his or her jurisdiction if the subject matter of the investigation originates inside city limits. Nunn, 121 So.3d at 568; State v. Allen, 790 So.2d 1122, 1125 (Fla. 2d DCA 2001); State v. Price, 589 So.2d 1009, 1010 (Fla. 4th DCA 1991); Wilson v. State, 403 So.2d 982, 984 (Fla. 1st DCA 1980). Thus, the investigatory acts of an officer outside of his or her jurisdiction are not deemed unlawful if during the investigation the officer has a good faith belief that the crime occurred within his or her jurisdiction.

  8. Knight v. State

    154 So. 3d 1157 (Fla. Dist. Ct. App. 2014)   Cited 4 times

    One exception allows an officer to act outside of his or her jurisdiction if the subject matter of the investigation originates inside city limits. Nunn, 121 So.3d at 568 ; State v. Allen, 790 So.2d 1122, 1125 (Fla. 2d DCA 2001) ; State v. Price, 589 So.2d 1009, 1010 (Fla. 4th DCA 1991) ; Wilson v. State, 403 So.2d 982, 984 (Fla. 1st DCA 1980). Thus, the investigatory acts of an officer outside of his or her jurisdiction are not deemed unlawful if during the investigation the officer has a good faith belief that the crime occurred within his or her jurisdiction.

  9. Nunn v. State

    121 So. 3d 566 (Fla. Dist. Ct. App. 2013)   Cited 7 times   1 Legal Analyses

    See Moncrieffe v. State, 55 So.3d 736, 740 (Fla. 4th DCA 2011). Thus, in Wilson v. State, 403 So.2d 982, 983 (Fla. 1st DCA 1980), the defendant's statements on a recorded call were suppressed when all of the defendant'sacts occurred outside of the city limits. Although an officer can conduct investigations outside of his or her jurisdiction acting as a private citizen, the First District held that an officer is not entitled to the benefit of the law enforcement exception to the all-party consent rule when doing so.

  10. Nunn v. State

    No. 4D10-5213 (Fla. Dist. Ct. App. Jun. 12, 2013)

    See Moncrieffe v. State, 55 So. 3d 736, 740 (Fla. 4th DCA 2011). Thus, in Wilson v. State, 403 So. 2d 982, 983 (Fla. 1st DCA 1980), the defendant's statements on a recorded call were suppressed when all of the defendant's acts occurred outside of the city limits. Although an officer can conduct investigations outside of his or her jurisdiction acting as a private citizen, the First District held that an officer is not entitled to the benefit of the law enforcement exception to the all-party consent rule when doing so.