STATE OF FLORIDA
v.
O'SHAWN NARFETIA KING
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The State appealed the trial court's order suppressing evidence of a firearm found during a search of the defendant's bedroom. The appellate court reversed, holding that the defendant's mother had valid common authority to consent to the search, making the suppression order erroneous.
The court held that the trial court erred in granting the motion to suppress because the undisputed facts established as a matter of law that the defendant's mother validly consented to the search of the bedroom where the firearm was found in plain view in an open drawer.
[1] A mother with common authority over a defendant's bedroom may validly consent to a search of that bedroom.
[2] A firearm found in plain view in an open drawer during a consent search is lawfully seized.
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Join FLexlaw to unlock all legal intelligence“the undisputed facts—which were recorded on the testifying officer's body camera—established as a matter of law that Appellee's mother validly consented to the search of Appellee's bedroom”
Establishes the basis for reversal: the mother had valid common authority to consent to the search based on undisputed facts captured on video
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Join FLexlaw to unlock all legal intelligenceOfficers conducted a search of O'Shawn Narfetia King's bedroom based on consent from his mother. A firearm was found in plain view in an open drawer. …
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FIFTH DISTRICT COURT OF APPEAL STATE OF FLORIDA Case No. 5D2024-3357 LT Case No. 16-2023-CF-2127-A STATE OF FLORIDA, Appellant, V. O'SHAWN NARFETIA KING, Appellee.
On appeal from the Circuit Court for Duval County. Jonathan D. Sacks, Judge. James Uthmeier, Attorney General, and Miranda L. Butson, Assistant Attorney General, Tallahassee, for Appellant. Matthew J. Metz, Public Defender, and Ali L. Hansen, Assistant Public Defender, Daytona Beach, for Appellee. March 6, 2026 PER CURIAM. This is an appeal by the State from the trial court's order granting Appellee's motion to suppress.
We agree with the State that the trial court erred in granting the motion because the undisputed facts which were recorded on the testifying officer's body camera-established as a matter of law that Appellee's mother validly consented to the search of Appellee's bedroom
where a firearm was found in plain view in an open drawer. See Preston v. State, 444 So. 2d 939, 943 (Fla. 1984) (holding that defendant's mother had common authority to consent to the search of defendant's bedroom where she had access to the room, defendant did not lock the room or instruct his mother not to let anyone enter the room, and articles were left out in the open), vacated on other grounds, 564 So. 2d 120 (Fla. 1990); Spinkellink v. State, 313 So. 2d 666, 669 (Fla. 1975) (upholding the seizure of a gun that was found in “plain view” in a partially opened kitchen drawer pursuant to a consent search).
In light of this conclusion, we do not address the State's other arguments. REVERSED and REMANDED. JAY, C.J., and WALLIS and MACIVER, JJ., concur. Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. 2
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- Preston v. State, 444 So. 2d 939 (Fla. 1984)
- Simkins Indus., Inc. v. Moreira, 313 So. 2d 666 (Fla. 1975)
- Preston v. State, 564 So. 2d 120 (Fla. 1990)