Supreme Court of Florida

State of Florida v. Johnathan David Garcia

October 27, 2022350 So. 3d 322

Summary

The court quashed the district court's grant of certiorari because Garcia could obtain review of any prejudice from compelled passcode disclosure after a final judgment, so he failed to show the irreparable harm required for certiorari jurisdiction. The court alternatively concluded that the trial court's order did not violate a clearly established legal principle because the Fifth Amendment issue was unsettled. The court therefore did not decide whether compelled smartphone passcode disclosure is testimonial or otherwise protected by the Fifth Amendment.