Com. v. Taylor, A.
529 WDA 2016
| Pa. Super. Ct. | Oct 12, 2017Background
- On April 28, 2015 police stopped a gray Suzuki for an expired inspection sticker; Andre Taylor was a front-seat passenger.
- Detective Schelley Gould approached, observed both driver and passenger "shaking" and nervous; ran license/warrant checks which came back clear.
- After returning the driver’s information, Gould delayed issuing a citation, radioed for backup, and remained at the vehicle; he later asked Taylor if he had anything on him.
- Gould admitted he had no sight of weapons or drugs and that his decision to continue the encounter was based on his "intuition" and a "hunch."
- Taylor said he had "a little bit of weed," was arrested, and later convicted after the trial court denied his suppression motion.
- The Superior Court reversed: it held the officer lacked particularized reasonable suspicion to extend the stop, reversed the suppression ruling, vacated the sentence, and remanded for further proceedings.
Issues
| Issue | Commonwealth's Argument | Taylor's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was unlawfully extended without reasonable suspicion (constitutes an investigative detention) | Nervous behavior and continued movement by driver and passenger created reasonable suspicion to prolong the stop for officer safety and investigation | Officer lacked particularized, objective facts; he acted on a hunch/intuition, so further detention violated Rodriguez and state law | The extension was unlawful; officer relied on intuition/hunch only, not articulable facts — suppression reversed and case remanded |
Key Cases Cited
- Rodriguez v. United States, 135 S. Ct. 1609 (U.S. 2015) (traffic stop may not be prolonged absent reasonable suspicion)
- Commonwealth v. Reppert, 814 A.2d 1196 (Pa. Super. 2002) (reasonable suspicion requires particularized, objective basis—nervousness alone is a hunch)
- Commonwealth v. Ranson, 103 A.3d 73 (Pa. Super. 2014) (standard of review for suppression rulings)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigative detentions require reasonable suspicion)
- Commonwealth v. Arch, 654 A.2d 1141 (Pa. Super. 1995) (officer hunch insufficient for detention)
- Commonwealth v. Dales, 820 A.2d 807 (Pa. Super. 2003) (cannot use information obtained during improperly prolonged stop to justify detention)