Porter v. State - 765 So. 2d 76 (Fla. Dist. Ct. App. 2000)

Rule:

The fresh pursuit exemption allows officers who attempt to detain or arrest within their territorial jurisdiction to continue to pursue a fleeing suspect even though the suspect crosses jurisdictional lines. The power to arrest after fresh pursuit presupposes that the officer had legally sufficient grounds to detain or arrest before they left their jurisdiction.

Facts:

Defendant was arrested after a high-speed vehicle pursuit in a vehicle that matched the description of one involved in an armed robbery. Defendant moved to suppress because the officers who arrested him were from a jurisdiction other than that in which they arrested defendant. The trial court denied the motion to suppress and defendant was convicted of robbery with a weapon. Defendant appealed his conviction. 

Issue:

Should the trial court have suppressed evidence because the officers who effected the search and seizure were from a different jurisdiction? 

Answer:

No.

Conclusion:

The court affirmed, finding that the arresting officers acted without unnecessary delay, their pursuit of the defendant was continuous and uninterrupted, and there was a close temporal relationship between the commission of the offense and the commencement of the pursuit and apprehension of the suspect. Therefore, defendant's arrest occurred during the course of his fresh pursuit by the arresting officers and was permissible.