Davis v. State

We affirm the denial of defendant’s motion to suppress cocaine found from a search of his person after his arrest for trespass. The search was valid as having been incident to a lawful arrest. See Moreland v. State, 552 So.2d 937, 939 (Fla. 2d DCA 1989), review denied, 562 So.2d 346 (1990). An arrest need only be supported by probable cause, see, e.g., Dunaway v. New York, 442 U.S. 200, 208, 99 S.Ct. 2248, 2254, 60 L.Ed.2d 824, 833 (1979), not necessarily a prima facie case. See Spinelli v. United States, 393 U.S. 410, 419, 89 S.Ct. 584, 590, 21 L.Ed.2d 637, 645 (1969) (“[0]nly the…