Florida Halo Law: Violations, Recording Police, and Court Challenges

Florida’s Halo Law makes it a second-degree misdemeanor to knowingly come within 25 feet of a first responder, after being verbally warned to stay back, with intent to interfere with their work, threaten them, or harass them. It took effect January 1, 2025, and is codified at Florida Statutes § 843.31. A conviction carries up to 60 days in jail or a $500 fine.¹

What Counts as a Violation

Three things have to line up before the statute applies. First, the person you’re near has to be a “first responder” performing official duties. The law covers law enforcement officers, correctional probation officers, firefighters, and emergency medical personnel.¹

Second, you have to have received a verbal warning not to approach. The statute is triggered by that warning; without it, the 25-foot zone does not legally exist for you. Third, after the warning, you have to knowingly and willfully come within 25 feet with one of the specified intents: to impede or interfere with the responder’s work, to threaten physical harm, or to harass.¹

Simply standing 25 feet away is not a crime. Neither is approaching without having been warned. The intent element is what supporters point to when they argue the law does not reach ordinary bystanders, though critics say “harass” and the associated “substantial emotional distress” threshold are subjective enough to swallow the limit.²

How the Law Has Been Used So Far

By the end of April 2025, at least 11 people had been arrested under the statute.² Early cases show the range of conduct officers have treated as violations, and how those cases have fared.

The first known arrest happened in the opening hour of the law’s existence. At 1 a.m. on January 1, 2025, Bay County deputies arrested Katelynn Justice, 29, at a Panama City Beach bar after she tried to check on her husband, who was being detained. The arrest report described her as “hovering.” Justice said she was never warned to keep her distance and did not know the law existed. Prosecutors dropped the charge on February 10, 2025, without publicly explaining why.³²

The first known conviction was Angel Morales, 35, of Fort Lauderdale. Broward deputies said he approached them during a Dania Beach traffic stop in February 2025 and shouted, “Do you want to get hurt?” A magistrate convicted him of violating the Halo Law and resisting an officer without violence five days later, and sentenced him to 10 days in jail.³

The most contested case is out of Jacksonville. On October 7, 2025, a crowd gathered outside an IDEA charter school as Officer Randy Holton tried to arrest Erika McGriff, who had allegedly left her car in an intersection. During the struggle, McGriff allegedly bit the officer. Anita Gibson, 59, and Jasmine Jefferson, 36, were arrested under the Halo Law, accused of entering the 25-foot zone and harassing Holton. Jefferson said she was actually arrested later at the police station, after going there believing she was giving a statement to Internal Affairs, and spent 72 hours in jail.⁴⁵

Attorneys Ben Crump and Harry Daniels demanded that State Attorney Melissa Nelson drop the charges, calling the statute “vague and ambiguous and arbitrary and capricious” and saying officers failed to issue the required verbal warning until after McGriff was already handcuffed in the patrol car.⁵ The charges against Gibson and Jefferson remained pending as of the most recent reporting.⁶

Does It Prohibit Recording the Police

The statute does not mention recording, and it does not explicitly exempt it either. Supporters say filming remains lawful so long as you stay outside the 25-foot zone. Polk County Sheriff Grady Judd stated the supporters’ position directly: “You can video law enforcement officers, that’s your constitutional right. But you’ve got to stay out of their way while they’re doing their jobs.”⁷

Press freedom advocates are less confident. Bobby Block of the First Amendment Foundation has said filming could be interpreted as causing “substantial emotional distress,” which is the standard tied to the harassment prong. That reading would let an officer use the statute against a person who is doing nothing but recording.⁷ The Eleventh Circuit has recognized a First Amendment right to record police in public, subject to reasonable time, place, and manner restrictions, but no Florida court has yet ruled on whether a 25-foot buffer is a reasonable one under the state’s statute.⁸

The practical answer, for now: recording from beyond 25 feet is clearly outside the statute. Recording inside 25 feet, after a warning, puts you in territory that has not been tested in a Florida appellate court.

Constitutional Challenges and What Other States Have Done

The ACLU of Florida formally opposed the bill during the legislative process, arguing it criminalizes ordinary bystanders and gives officers unchecked discretion.⁹ John W. Whitehead of the Rutherford Institute called the law “riddled with vague terms.”⁷ No federal court has yet ruled on the Florida statute itself. The Jacksonville case has been floated as a possible vehicle for such a challenge.⁸

Similar buffer zone laws in other states have not fared well:

Arizona’s version was struck down as unconstitutional in 2022.¹⁰
On August 5, 2025, the Seventh Circuit affirmed an injunction against Indiana’s original buffer law, finding it unconstitutionally vague. Judge Doris Pryor wrote that “the Fourteenth Amendment will not tolerate a law subjecting pedestrians to arrest merely because a police officer had a bad breakfast.”¹¹
A federal judge blocked Louisiana’s nearly identical law in January 2025, calling it “unconstitutionally void for vagueness” with a “chilling effect” on newsgathering. The Fifth Circuit heard oral arguments on June 1, 2026, with a ruling expected later that year.¹²
In Tennessee, U.S. District Judge William Campbell denied media plaintiffs a preliminary injunction on February 17, 2026, though he did not rule on the merits; the plaintiffs appealed to the Sixth Circuit. In May 2026, the ACLU filed Demster v. Blanche in the Western District of Tennessee on behalf of four Memphis residents who allege a federal task force used the state’s Halo Law to retaliate against them for recording police. That case is pending.¹³¹⁴¹⁵¹⁶

A Possible Expansion to Federal Agents

In February 2026, Florida Chief Financial Officer Blaise Ingoglia began drafting legislation to extend the 25-foot buffer to federal law enforcement, including ICE and Homeland Security agents during operations such as immigration raids. Ingoglia said the goal was to prevent people from approaching or filming federal agents during those operations.¹⁷ Criminal defense attorney Matt Landsman warned the expansion could further erode the right to record law enforcement in public.¹⁸ As of mid-2026, the proposal had not advanced to a formal committee vote, and the current statute still applies only to state and local first responders.

1
The Florida Legislature. F.S. 843.31 — Approaching a First Responder With Specified Intent After a Warning
2
WUFT. Florida Begins First Prosecutions Under Controversial Halo Law
3
Sun Sentinel. Florida Begins Prosecutions Under Controversial Halo Law
4
Jacksonville Sheriff’s Office. BOLEO and Halo Law
5
News4Jax. Civil Rights Attorneys Argue Florida’s Halo Law Is Unconstitutional
6
Jacksonville.com. Attorneys Want Justice for the Jacksonville Three After Viral Arrest
7
NBC Miami. Florida’s Halo Law Aims to Protect First Responders — Here’s What to Know
8
Florida Today. ICE Immigration Enforcement, Police, Florida Recording Law
9
ACLU of Florida. ACLU FL Opposition to SB 184-HB 75 — Criminalizing Bystanders
10
Verite News. Injunction Blocks Police Buffer Zone Law
11
U.S. Court of Appeals for the Seventh Circuit. Reporters Committee for Freedom of the Press v. Rokita
12
Courthouse News Service. Fifth Circuit Split on Louisiana Police Buffer Zone Law
13
Reporters Committee for Freedom of the Press. Gannett Co. v. Long
14
The Tennessean. TN Buffer Zone Law — Judge Declines Injunction
15
ACLU of Tennessee. Memphis Residents Challenge Pattern of Retaliation for Recording Memphis Safe Task Force Agents
16
CourtListener. Demster v. Blanche, No. 2:26-cv-02546
17
Florida Politics. Blaise Ingoglia Proposes Halo Act Protections for Federal Agents in Florida
18
WESH. Florida CFO Proposes Expanding Halo Act to Protect Federal Agents