Com. v. Griffen-Jacobs, D., 1891 EDA 2016

Shortly after midnight, officers heard 3–4 gunshots and drove toward the sound in an unmarked car in a Philadelphia neighborhood.
Officers encountered Griffen-Jacobs walking alone near the source of the shots with his left hand in his pocket; no visible bulge was observed.
Officers identified themselves and ordered him to stop; he ignored commands and began to flee after officers moved to block his path.
While fleeing, Griffen-Jacobs discarded a silver revolver into a vacant lot and was apprehended.
He was charged with possession by a prohibited person, carrying firearms without a license, and carrying firearms in public; he moved to suppress the firearm as the product of an unlawful stop and "forced abandonment."
The trial court denied suppression; after a bench trial he was convicted and sentenced to 5–10 years plus five years probation. The Superior Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether police had reasonable suspicion to effect an investigative detention	Commonwealth: officers had reasonable suspicion based on recent nearby gunfire, location, and Appellant’s presence and conduct	Griffen-Jacobs: merely walking on phone with hand in pocket; no bulge or furtive movement; had right to ignore officers; area not established as high-crime	Court: reasonable suspicion existed given gunshots nearby, Appellant alone at source location at night, apparent manipulation in pocket, and officer familiarity with area; stop justified
Whether the firearm should be suppressed under the "forced abandonment" doctrine (Matos) because the stop was unlawful	Commonwealth: stop was lawful so Matos forced-abandonment suppression inapplicable	Griffen-Jacobs: if stop was unlawful, the gun was abandoned due to illegal seizure and should be suppressed	Court: because the detention was supported by reasonable suspicion, forced-abandonment suppression did not apply; evidence admissible

Commonwealth v. Matos, 672 A.2d 769 (Pa. 1996) (articulates forced-abandonment suppression rule)
Commonwealth v. Bryant, 866 A.2d 1143 (Pa. Super. 2005) (hearing gunshots and observing persons near source can supply reasonable suspicion)
Commonwealth v. Jeffries, 311 A.2d 914 (Pa. 1973) (mere flight in daylight without other suspicious facts insufficient for reasonable belief of criminal activity)
Commonwealth v. Yandamuri, 159 A.3d 503 (Pa. 2017) (standard of review for suppression rulings)
Commonwealth v. Baldwin, 147 A.3d 1200 (Pa. Super. 2016) (summarizes encounter categories and reasonable suspicion standard)
Commonwealth v. Williams, 125 A.3d 425 (Pa. Super. 2015) (reasonable suspicion requires more than an unparticularized hunch)