Com. v. Williams, D., 2439 EDA 2016

On May 8, 2015, Officer Moore received radio information about a shooting on the 3400 block of I Street in North Philadelphia; no suspect description was provided.
About 30–90 minutes later, Moore observed Dexter Williams walking on nearby H Street; Williams was tugging/adjusting his waistband, walking briskly, looked back at a marked patrol car, made a U‑turn, and went onto a porch while continuing to adjust his waistband.
Officers exited their vehicles and ordered Williams to show his hands; he wedged himself between a screen and front door so his hands were momentarily out of view; officers drew weapons after he failed to comply.
Williams discarded a small black firearm from his right hand; officers recovered the gun, arrested him, and found jars of marijuana and $779 on him.
Williams moved to suppress the evidence as the product of an unlawful stop/search; the trial court denied suppression, convicted him after a bench trial of marijuana possession and several firearms offenses, and sentenced him to 6½–15 years. The Superior Court affirmed.

Issue	Appellant's Argument	Commonwealth's Argument	Held
Whether the officers had reasonable suspicion to detain Williams and investigate for weapons	Williams: Police lacked sufficient specific facts to reasonably suspect criminal activity or that he was armed and dangerous	Police: Totality of circumstances (high‑crime area, proximity to recent shooting, evasive behavior, waistband tugging, looking back at patrol car) provided reasonable suspicion	Court: Arrest/detention justified — officers had reasonable suspicion; when Williams discarded a gun, probable cause arose

Terry v. Ohio, 392 U.S. 1 (establishes that officers may conduct limited stops and weapons searches based on specific and articulable facts)
Illinois v. Wardlow, 528 U.S. 119 (unprovoked flight or evasive behavior in a high‑crime area is a relevant factor for reasonable suspicion)
Navarette v. California, 134 S. Ct. 1683 (reasonable suspicion must be particularized to the person stopped; totality of circumstances applies)
Commonwealth v. Cook, 735 A.2d 673 (courts must consider totality of circumstances and afford weight to reasonable inferences from officer experience)
Commonwealth v. Dixon, 997 A.2d 368 (totality of circumstances governs reasonable suspicion analysis)
Commonwealth v. Carter, 105 A.3d 765 (suppression analysis requires examining circumstances known to the officer ex ante)
Commonwealth v. McCoy, 154 A.3d 813 (standard of review for suppression denials — appellate courts accept suppression court’s factual findings if supported)