Commonwealth v. Singletary

The Pennsylvania Superior Court affirmed the trial court’s order to suppress a gun. A police officer saw an SUV that was not running, parked in a legal parking spot, with two individuals sitting in the front seats. The defendant was in the front passenger seat. The officer approached the driver’s side of the vehicle and requested identification. The officer then determined that the driver’s license was suspended, that the vehicle came back as no record found, listed no insurance, and that neither occupant owned the SUV. The officer observed an empty pill bottle in the driver’s lap, which he determined—based on the label—might have, at some point, contained oxycodone prescribed to someone other than the vehicle’s occupants. Another officer arrived on the scene and stood at the passenger’s door. The officers asked the occupants to exit the vehicle. As the defendant got out of the vehicle, the officers heard a metal object hit the ground, at which point the defendant ran away. The officers recovered a firearm with an obliterated serial number from the location where they heard the sound of a metal object. Later that day, the defendant was arrested and charged with violations of the Uniform Firearms Act. The defendant filed a suppression motion, which the trial court granted. The Commonwealth appealed, and the Superior Court affirmed. The Court held that the interaction “evolved into an investigatory detention without reasonable suspicion when the officers stood on each side of the SUV, and requested the occupants to alight from the vehicle, all while the occupants’ identifications remained in police possession. At the time of the officers’ request to alight from the vehicle, their body positions on either side of the SUV restrained the defendant’s liberty of movement”. Moreover, the vehicle stop was concluded by the time the officers requested that the defendant get out of the vehicle. There was no further investigation to conduct related to any driving infraction, vehicle registration infraction, or vehicle insurance infraction, and the officers declined to write a ticket or issue a warning. Next, the Court ruled that the officers did not have reasonable suspicion when they seized the defendant because the officer failed to articulate specific observations that led him reasonably to conclude that criminal activity was afoot and that the defendant was involved in that activity. “There was no evidence that the defendant was connected to any of the Commonwealth’s evidence”.

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