The FBI shows up to a man’s home with 80 agents, an armored tank, and a sealed federal warrant — and when he asks to see it, nobody shows him one. Then local police arrive, make arrests, and tell the court: “There was a federal warrant. Trust us.” A Florida appeals court just said that’s not how the Fourth Amendment works.
What Happened
On December 20, 2022, Leonardo Cabrera was home at his Miami-Dade property — surrounded by a six-foot fence — when the FBI descended with over 80 agents and an armored vehicle. Agents busted his door open, broke a shed, and damaged his car. Cabrera asked to see a search warrant. No one showed him one. No one spoke to him.
After the FBI wrapped up, Miami-Dade Detective Rodriguez entered the property and observed cockfighting paraphernalia. He later used what he personally saw to apply for a state search warrant the next day. Cabrera was charged with two cockfighting-related counts and one count of animal cruelty.
Case Timeline
- December 20, 2022: FBI raids with 80+ agents. No warrant shown. No consent given.
- Same day: Detective Rodriguez enters property, observes evidence, conducts post-Miranda interview, arrests Cabrera.
- December 21, 2022: State warrant executed — based entirely on Rodriguez’s observations from his warrantless entry the day before.
- January 18, 2023: State files charges. Defense files motion to suppress all evidence and statements.
- Trial court: Motion denied. Judge applies “good faith” exception without ever seeing the federal warrant.
- May 13, 2026: Florida 3rd DCA reverses. All evidence and statements suppressed. Motion to suppress must be granted on remand.
Why the Court Threw Everything Out
The core problem: the federal warrant was sealed. The FBI refused to produce it. Neither the trial court, the defense, nor Detective Rodriguez himself had ever seen it. Yet the trial court denied the motion to suppress anyway — skipping the warrant analysis and applying the “good faith exception” on the theory that all those federal agents must have had a legitimate reason to be there.
Florida’s Third District said that reasoning doesn’t hold. Here’s why:
- No warrant, no good faith exception. The exception requires a court to actually review the four corners of the warrant and affidavit. You can’t apply it in a vacuum. The trial court even admitted it couldn’t evaluate the warrant — which is precisely the problem.
- The burden shifts to the State. Once a defendant shows a warrantless search occurred, the State must prove it was lawful. Pointing to a sealed document it refuses to produce doesn’t meet that burden.
- The fellow officer rule has limits. Florida’s collective knowledge doctrine lets state officers rely on federal information — but only if someone with actual knowledge of the warrant’s contents testifies. Nobody did.
- Fruit of the poisonous tree. Because Rodriguez’s entry onto the fenced property was unlawful, Cabrera’s post-arrest statements were also suppressed — even though Miranda warnings had been given.
- No other exceptions applied. Cabrera never consented. The cockfighting materials were not in plain view — Rodriguez only saw them after entering. No exigent circumstances were claimed.
The Takeaway
This case is a clean application of well-established Fourth Amendment law, but the situation that produced it matters. When federal and state agencies team up, accountability can fall through the cracks. The feds hold the warrant but it’s sealed. The state officer acts on what he’s told but can’t verify it. Then the State tries to prosecute using evidence from a search nobody can justify on paper.
Florida’s Third District is saying clearly: the good faith exception is a defense, not a blank check. You can’t assert it without opening the file.
Frequently Asked Questions
What did the court decide in Cabrera v. State (2026)?
The Florida Third District Court of Appeal reversed the trial court and ordered all evidence suppressed. The State cannot rely on a sealed federal warrant it refuses to produce, and the good faith exception does not apply when neither the warrant nor its affidavit is in the record.
What is the good faith exception and why did it not apply here?
The good faith exception allows courts to admit evidence obtained by officers who reasonably relied on a warrant later found defective. But applying it requires the court to actually review the warrant and affidavit. In Cabrera, the federal warrant was sealed and never produced, so there was no basis to apply the exception.
What is the fellow officer rule in Florida?
Florida’s fellow officer rule allows a state officer to rely on information from federal agents to establish probable cause. However, at least one officer in the chain must actually know the facts justifying the search. In Cabrera, no officer testified to knowing the contents of the federal warrant, so the rule could not save the search.
What does “fruit of the poisonous tree” mean?
Fruit of the poisonous tree requires courts to suppress not just evidence from an illegal search, but also any statements or secondary evidence derived from it. In Cabrera, because the entry was unlawful, the defendant’s post-arrest statements were also suppressed even though Miranda warnings had been given.
Can I suppress evidence from a joint federal-state search in California?
Potentially yes. If state officers participated in a search based on a federal warrant that was never verified or produced, you may have grounds to file a motion to suppress. The same Fourth Amendment principles apply in California courts. Contact LAWSTACHE Law Firm at (619) 357-6677 for a free consultation.
What happens if a motion to suppress is granted?
If a motion to suppress is granted, the unlawfully obtained evidence and any statements derived from it cannot be used at trial. Depending on how much the prosecution’s case relies on that evidence, a successful suppression motion can lead to reduced charges or dismissal.
Was Your Home Searched Without a Proper Warrant?
If law enforcement searched your property in San Diego or anywhere in California — especially during a joint federal-state investigation — you may have grounds to suppress the evidence. The attorneys at LAWSTACHE know how to challenge these searches.
Call (619) 357-6677 today for a free consultation with Anton Vialtsin, Esq.
Anton Vialtsin, Esq.
LAWSTACHE™ LAW FIRM | Criminal Defense and Business Law
https://lawstache.com
(619) 357-6677
Case citation: Cabrera v. State, — So.3d —-, 2026 WL 1321018 · Florida Third District Court of Appeal · Opinion Filed May 13, 2026 · Lower Tribunal No. F22-23260