Grand Theft of Motor Vehicle, 13 counts of Uttering False Bank Instruments, 13 counts of Possession of Counterfeit Bank Instruments, 13 counts of Counterfeiting Pay Instruments with Intent to Defraud, and Possession of 10 or More Forged Instruments — more than 40 felony counts in total
The client was stopped on I-75 by a Florida Highway Patrol Criminal Interdiction Unit trooper for suspected window tint. Investigation revealed the client was driving a stolen BMW X6 with a tampered VIN and multiple fraudulent license plates. A K9 search of the vehicle uncovered 13 counterfeit Western Union money orders totaling $13,000 inside a sealed envelope, along with a loaded firearm and additional contraband. The State filed over 40 felony counts spanning theft, fraud, and counterfeiting statutes.
Counsel conducted a thorough review of the stop and search and identified multiple Fourth Amendment issues — including an argument that the traffic stop was unlawfully extended under Rodriguez v. United States to deploy the K9 without independent reasonable suspicion, and a separate challenge to the warrantless search of a sealed container. These constitutional vulnerabilities were leveraged in negotiations rather than litigated, preserving the most favorable outcome for the client. The State agreed to no-file more than 38 of the charges. The three remaining counts were resolved with adjudication withheld across the board — meaning no felony conviction, no jail time, and no restitution.
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