Simpson v. State
970 So. 2d 463 (Fla. 2d DCA 2007) • No. 2D06-1859 • December 12, 2007
Holding: Reversed the suppression ruling and directed discharge. The owner’s insurance-related suspension did not supply continued suspicion against the visibly different driver on the facts presented, given possible operator coverage.
Relevance: Match the return to the person and coverage obligation actually under investigation.
Limits: A stop/suppression case under earlier statutes, not a holding that ELVIS/DAVID proves—or never can support—an insurance offense. It establishes no insurer-call checklist or trial-proof rule.
Read opinion ↗State v. Brooks
295 So. 3d 348 (Fla. 2d DCA 2020) • No. 2D18-4300 • April 24, 2020
Holding: Reversed suppression/dismissal: multiple tag/VIN searches and the surrounding facts supported probable cause to arrest for operating an unregistered vehicle after renewed driving. The suppression hearing required probable cause, not proof that the car was actually unregistered.
Relevance: Illustrates evaluation of reasonably trustworthy database information in context and the distinction between probable cause and ultimate proof.
Limits: Registration under Chapter 320, not insurance under Chapter 324. Its three searches are facts, not a mandatory number of checks or a rule that an insurance return alone is enough. This is the 2020 Eric Brooks case, not the 1995 case at 662 So. 2d 440.
Read opinion ↗Opinions and citations reviewed October 21, 2026. Simpson uses the court’s opinion reproduced by Justia; Brooks links to the official court PDF. These summaries are not a comprehensive citator report.