Appellate Brief Scenario: for the State of Florida

Your client, Ms. Kimberly Hall, stands convicted under your state law for charges involving theft, trafficking in stolen property, fraud, and alteration of vehicle identification numbers. Hall runs a small salvage yard on a 3.5 acre piece of property surrounded by several fences, tall trees, dense scrub bushes, and posted No Trespassing signs. The property contains 2 structures: a small one-room cabin, in which Hall resides, and a separate structure, approximately 30 feet high, with sliding barn doors on all four sides, no windows, and no roof.

Early on the day of Hall's arrest, state and local authorities conducted a drone-surveillance sweep after an anonymous tip line received several calls reporting the operation of multiple automotive chop shops in a rural location within your state of residence. Captured video of the larger structure, obtained by the drone's camera from approximately 100 feet in the air and simultaneously transmitted to police officers on the ground, revealed the presence of multiple dismantled vehicles, a pile of license plates, various automotive parts and tools, including grinders, cutting saws, hoists and welding rigs. Hall was taken into police custody at approximately 5:00 a.m. that morning, and was subsequently charged based on that footage.

At trial, several residents claimed that the presence of the drones in the early morning hours resulted in unnecessary panic, which quickly swept the small community, and resulted in multiple calls to local police dispatch, some minor property damage, and at least one assault. Sally Jones, who lives adjacent to Ms. Hall, testified that, "Conner Peterson and those damned drones caused enough drama and paranoia to end a 25-year friendship in a fistfight." Conner Peterson, a survivalist/prepper and avid short-wave radio enthusiast, stated for the record that, on the morning of Hall's arrest, he was up late monitoring radio transmissions between members of a known local anti-government group who were discussing plans for "something big" involving the use of personal drones. Mr. Peterson stated that he heard an unusual buzzing noise coming from the west side of his property as he stood outside with his dog at approximately 4:00 a.m. When he spotted a drone hovering between his house and his garage, he immediately began calling to warn his neighbors that something was up, and to remain vigilant.

The trial court considered all testimony, exhibits, and arguments and found your client guilty.

State of Florida

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