Com. v. Maddox, J., Com. v. Maddox, J. No. 1848 EDA 2015

Police received an anonymous radio “flash” about a man with a gun near 6th and Glenwood at ~8:48 p.m.; description: Black male, ~50s, red Phillies cap, beige jacket, dark pants.
Officers patrolled and within minutes observed Appellant ~1–1.5 blocks from the reported location wearing a red Phillies cap, light-colored hoodie, and dark pants; Appellant was ~60 years old.
As officers approached in a marked car, Appellant changed direction, tried to enter a locked house (later identified as a relative’s home), and seemed to keep one hand near his waistband/pocket.
Officers exited the vehicle, ordered Appellant to show his hands; he refused, verbally protested, and a struggle ensued during which officers handcuffed him and felt a gun in his pocket while attempting to remove his hand.
Appellant was charged with multiple firearms offenses, moved to suppress the gun as the product of an illegal seizure, the suppression motion was denied, he was convicted at bench trial, and sentenced to 6–12 years; he appealed the denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the detention that produced the firearm was supported by reasonable suspicion	Commonwealth: Officers had reasonable suspicion based on the anonymous flash, Appellant’s close match to the description, proximity to the flash location, furtive behavior in a known high-crime area, and refusal to show hands	Maddox: Matching was cursory, he was at/near his relative’s home a block-and-a-half away, timing was uncertain, and no facts showed criminal activity justifying the stop	Denial of suppression affirmed: totality of circumstances (flash + proximity + high-crime area + furtive conduct + refusal to show hands) gave reasonable suspicion for an investigative detention

Commonwealth v. Sanders, 42 A.3d 325 (Pa. Super. 2012) (standard of review on suppression denial)
Commonwealth v. Ranson, 103 A.3d 73 (Pa. Super. 2014) (three levels of police–citizen interaction; need for reasonable suspicion for investigative detention)
Commonwealth v. Gutierrez, 36 A.3d 1104 (Pa. Super. 2012) (defining encounter, investigative detention, and arrest)
Commonwealth v. Freeman, 150 A.3d 32 (Pa. Super. 2016) (use totality of circumstances and officer inferences to assess reasonable suspicion)
Commonwealth v. Cook, 735 A.2d 673 (Pa. 1999) (weight given to officer experience and totality analysis)
Commonwealth v. Walls, 53 A.3d 889 (Pa. Super. 2012) (proximity to flash and matching description contribute to reasonable suspicion)
Commonwealth v. Scarborough, 89 A.3d 679 (Pa. Super. 2014) (refusal to show hands in a high-crime area can support reasonable suspicion)