Com. v. Eakin, S.
324 A.3d 591
Pa. Super. Ct.2024Background
- Chief Edward Sharp of the Polk Borough Police Department stopped Steven G. Eakin for driving in the wrong lane in Frenchcreek Township, a jurisdiction policed by Polk Borough under a joint municipal agreement since 2006.
- At the time of the stop, the Intergovernmental Cooperation Act (ICA) required both municipalities to adopt such agreements by ordinance; Frenchcreek adopted only a resolution, not an ordinance.
- Eakin was arrested for DUI following a blood draw after the stop. He moved to suppress the evidence, arguing the officers were acting outside their jurisdiction in violation of both the ICA and the Municipal Police Jurisdiction Act (MPJA).
- The trial court granted Eakin’s suppression motion, finding the officers lacked authority due to improper municipal procedures.
- The Commonwealth appealed, arguing suppression was too harsh a remedy for what it billed as a technical violation, and the case proceeded before the Pennsylvania Superior Court en banc.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether suppression is appropriate for ICA/MPJA violations | Technical violation—suppression not warranted. | Lack of proper ordinance makes agreement void, suppression required. | Suppression not appropriate; reverse and remand. |
| Applicability of Commonwealth v. Hlubin | Hlubin is distinct; stop here was outside checkpoint context. | Hlubin directly controls when suppression is appropriate. | Hlubin factually different, suppression unwarranted here. |
| Legislative intent and amendment of MPJA | Amendments to MPJA show legislature didn’t want suppression for these errors. | Prior law and technical compliance needed to validate stop. | Legislative changes indicate suppression not required. |
| Extent of deviation from MPJA/ICA | Good faith, minimal deviation, acted for public safety. | Substantial procedural deficiency vitiates jurisdiction. | Deviation was minor; officers acted in good faith. |
Key Cases Cited
- Commonwealth v. O'Shea, 567 A.2d 1023 (Pa. 1989) (establishes a case-by-case approach to suppression as a remedy for MPJA violations)
- Commonwealth v. Hlubin, 208 A.3d 1032 (Pa. 2019) (controls standards for suppression in multi-jurisdictional checkpoints)
- Commonwealth v. Lehman, 870 A.2d 818 (Pa. 2005) (authorizes exigent circumstances exceptions for extra-jurisdictional police actions)