District Court of Appeal of Florida September 27, 2012, No. 4D11-4096 (P.R. v. State)

TAYLOR, J.

Appellant challenges his conviction for possession of cannabis, arguing that the trial court erred in refusing to suppress evidence discovered during a search incident to his arrest. Because the officer lacked probable cause to arrest appellant for loitering and prowling, we reverse the denial of appellant’s motion to suppress.