Commonwealth v. Thomas

The Pennsylvania Superior Court was tasked with determining whether a suspect was stopped when an officer approached the suspect as he rode a bicycle and said, “Hold up for a second.” The Court held that the “interaction between the officers and Appellant was limited, informal, and carried all the hallmarks of a mere encounter.” As a result, there was no need for the officer to have reasonable suspicion, and the lower court’s order denying suppression was affirmed.

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