Com. v. Maldonado, D.
1781 MDA 2015
| Pa. Super. Ct. | Oct 7, 2016Background
- On Jan. 29, 2015, two plain‑clothes Lebanon County Drug Task Force detectives observed Daniel Maldonado briefly enter a parked car (~30 seconds), exit, and walk nearby in a high‑crime area.
- Detectives approached, identified themselves, asked to speak, requested ID, and said why they approached him; interaction lasted about 5–10 minutes.
- Maldonado produced ID; detectives ran warrants (negative) and asked about weapons/drugs and for consent to search. A pat‑down revealed a cigarette pack; inside was an atypical cigarette Maldonado admitted was marijuana.
- Maldonado was charged with possession of a small amount of marijuana and possession of paraphernalia; he moved to suppress the seized evidence.
- The suppression court found Maldonado was subjected to an investigative detention lacking reasonable suspicion and suppressed the evidence; Commonwealth appealed.
- The Superior Court affirmed, holding (1) the Commonwealth waived its consent argument, and (2) even on the merits the stop lacked reasonable suspicion and any consent was tainted by the illegal detention.
Issues
| Issue | Commonwealth's Argument | Maldonado's Argument | Held |
|---|---|---|---|
| Whether the encounter was a mere encounter or an investigative detention | Officers only asked to speak and identified themselves; interaction was consensual (mere encounter) | Officers’ words, request for ID, 2:1 presence, request to search, and 5–10 minute duration made a reasonable person feel not free to leave (detention) | Held: investigative detention, not mere encounter |
| Whether detectives had reasonable suspicion to detain Maldonado | Brief entry into car in a drug‑area + detectives’ experience supported reasonable suspicion of a drug transaction | Short car entry, location in daytime, and pacing are innocuous; detectives lacked articulable facts beyond hunch | Held: no reasonable suspicion — detention unlawful |
| Whether Maldonado consented to the search and whether consent validated the search | (On appeal) Maldonado voluntarily consented; search therefore lawful | Consent (even if given) was tainted by the illegal detention and thus involuntary/invalid | Held: Commonwealth waived consent claim; alternatively, consent would be vitiated by taint of illegal stop |
| Whether suppression court erred by considering officers’ subjective intent | Subjective intent cannot justify seizure; court improperly relied on officers’ investigatory intent | Officers’ stated reasons were communicated to Maldonado and thus relevant to objective inquiry | Held: officers’ communicated intent could be considered as part of the objective totality of circumstances but court correctly concluded detention occurred |
Key Cases Cited
- Stansbury v. California, 511 U.S. 318 (1994) (an officer's undisclosed subjective view does not affect custody analysis; communicated beliefs may be considered)
- Terry v. Ohio, 392 U.S. 1 (1968) (lawful investigative stop requires reasonable suspicion)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (presence in high‑crime area and flight may support reasonable suspicion only with particularized facts)
- Brown v. Illinois, 422 U.S. 590 (1975) (consent following illegal arrest requires government proof of break in causal chain)
- United States v. Melendez‑Garcia, 28 F.3d 1046 (10th Cir. 1994) (consent after illegal detention requires showing consent was independent of illegality)
- Commonwealth v. Sierra, 723 A.2d 644 (Pa. 1999) (Commonwealth bears burden to prove voluntariness of consent and any break in causal connection)
- Commonwealth v. McCree, 924 A.2d 621 (Pa. 2007) (warrantless searches are presumptively unreasonable; exceptions are narrowly construed)