State of Florida v. O'Shawn Narfetia King - Search Suppression Ruling
Summary
The Florida Fifth District Court of Appeal reversed a trial court's order suppressing evidence, finding that the mother's consent to search her son's bedroom was valid. The court remanded the case for further proceedings.
What changed
The Florida Fifth District Court of Appeal reversed a trial court's suppression ruling in State of Florida v. O'Shawn Narfetia King (Case No. 5D2024-3357). The appellate court found that the trial court erred in suppressing evidence obtained from a search of the appellee's bedroom, as the undisputed facts, recorded on body camera footage, established that the appellee's mother provided valid consent for the search. A firearm was found in plain view in an open drawer.
This decision means the evidence previously suppressed is now admissible, potentially leading to the continuation of the criminal proceedings against O'Shawn Narfetia King. The case is remanded to the trial court. Legal professionals involved in criminal defense and prosecution in Florida should note the appellate court's interpretation of consent to search, particularly when consent is given by a parent for a child's bedroom, and the significance of body camera footage in establishing the validity of such consent.
What to do next
- Review appellate court's reasoning on consent to search in State of Florida v. O'Shawn Narfetia King.
- Advise clients on potential implications for cases involving consent searches by family members.
- Ensure proper documentation and recording of consent for searches.
Source document (simplified)
Jump To
Support FLP
CourtListener is a project of Free
Law Project, a federally-recognized 501(c)(3) non-profit. Members help support our work and get special access to features.
Please become a member today.
March 6, 2026 Get Citation Alerts Download PDF Add Note
State of Florida v. O'Shawn Narfetia King
District Court of Appeal of Florida
- Citations: None known
Docket Number: 5D2024-3357
Combined Opinion
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
Related changes
Source
Classification
Who this affects
Taxonomy
Browse Categories
Get State Courts alerts
Weekly digest. AI-summarized, no noise.
Free. Unsubscribe anytime.
Get alerts for this source
We'll email you when FL District Court of Appeal Opinions publishes new changes.