M.J. v. State
Florida District Court of Appeal
121 So. 3d 1151 (2013)
- Written by Caitlinn Raimo, JD
Facts
A police officer was on patrol on a weekday when he observed M.J. (defendant), a 17-year-old child, in front of a home. Because the police officer had previous encounters with M.J. and knew he should have been in school, he initiated a truancy investigation. Upon spotting the officer, M.J. ran. When the officer located and approached M.J., he read M.J. his Miranda rights and inquired as to his purpose at the house. M.J. claimed to have been visiting a friend, but the officer did not believe him because when he knocked on the front door, no one answered for a few moments. A second officer arrived and located three pairs of new sneakers near the house. The home’s resident then appeared, and the second officer recognized the resident as having been previously involved in burglaries. M.J. was arrested for loitering and prowling. After transporting M.J. to the station, the officer learned that the sneakers had been stolen. M.J. then confessed to burglary. M.J. moved to suppress his confession. The trial court denied the motion, finding that the officer was justified in arresting M.J. for loitering and prowling based on his actions of running and hiding from the officer and vague response to his purpose at the house. M.J. pleaded guilty, then appealed the denial of his motion to suppress.
Rule of Law
Issue
Holding and Reasoning (Warner, J.)
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