Com. v. Cooper, A.
Com. v. Cooper, A. No. 1080 EDA 2016
| Pa. Super. Ct. | Apr 26, 2017Background
- On May 27, 2014, Officer Kevin Fritchman observed a gold Honda CR‑V reported stolen; he initially saw Cooper in the driver’s seat and later saw the vehicle again several blocks away.
- Officer Fritchman stopped the Honda; both occupants fled on foot and Cooper was captured after a short chase and taken into custody on automobile-theft related charges.
- While in custody after the vehicle stop, Cooper gave a detailed statement confessing to a separate April 30, 2014 convenience‑store robbery in which a clerk was shot; physical evidence from the stolen car (backpack, gloves, zip ties) corroborated aspects of the robbery investigation.
- Cooper moved to suppress (1) evidence from the vehicle stop/arrest arguing lack of probable cause and (2) his custodial statement arguing involuntariness due to delay/conditions; the suppression court denied both motions.
- After denial, a jury convicted Cooper of aggravated assault, robbery, conspiracy, possessing an instrument of crime and related firearm offenses; he was sentenced to an aggregate 15–30 years. Cooper appealed; the Superior Court affirmed.
Issues
| Issue | Appellant's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Validity of vehicle stop/arrest (probable cause) | Officer lacked probable cause because Cooper was not observed driving the stolen car and was later found in the passenger seat | Officer had reasonably trustworthy information that the car was stolen and observed Cooper in the driver’s seat earlier, supporting probable cause to arrest for receiving stolen property | Denied suppression; probable cause existed based on totality (stolen-vehicle report + officer's observations) |
| Voluntariness of custodial statement | Statement involuntary due to lengthy delay (≈8 hrs), interrogation tactics, and execution of an unrelated search warrant that coerced a confession | Delay was explained by investigative steps (obtaining/executing a search warrant); Miranda warnings were given; conditions (breaks, food, no threats) do not show coercion | Denied suppression; statement was knowing, voluntary, and intelligent under totality of circumstances |
Key Cases Cited
- Commonwealth v. Jones, 121 A.3d 524 (Pa. Super. 2015) (standard of review for suppression rulings)
- Commonwealth v. Simmen, 58 A.3d 811 (Pa. Super. 2012) (probable cause defined by totality of circumstances)
- Commonwealth v. Canning, 587 A.2d 330 (Pa. Super. 1991) (probable cause requires probability, not prima facie proof)
- In Interest of Scott, 566 A.2d 266 (Pa. Super. 1989) (addressed sufficiency of evidence for receiving stolen property in juvenile context)
- Commonwealth v. Bryant, 67 A.3d 716 (Pa. 2013) (voluntariness tested by totality of circumstances; lengthy detention not dispositive)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requirement to advise custodial suspects of rights)