Com. v. Young, E., Com. v. Young, E. No. 573 EDA 2016

On Oct. 2, 2015, Edward Young was stopped by three plainclothes Philadelphia officers near 1413 W. Erie Ave., an area the officers described as a violent, high‑narcotics location.
Officers in an unmarked car returned after about an hour, identified themselves, and asked Young what he was doing and whether he had anything that could harm officers.
Young replied he was waiting for a bus and volunteered that he had “two bags of weed,” then began to reach for his pocket.
Officer Nieves told Young not to reach and reached into Young’s coat pocket, retrieving a loaded .380 handgun; another officer recovered marijuana from Young’s pants pocket.
Young was charged with firearms and drug offenses and moved to suppress the gun and marijuana, arguing his detention and arrest were unlawful.
The trial court granted suppression; the Commonwealth appealed. The Superior Court reversed, holding the initial contact was a mere encounter and Young’s admission provided probable cause to arrest and search incident to arrest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had legal basis to detain/search Young after approaching him and asking questions in a high‑crime area	Commonwealth: the officers had probable cause (or at least reasonable suspicion) once Young admitted possession of marijuana and reached for his pocket	Young: the encounter escalated into an illegal investigative detention/arrest and the evidence should be suppressed	Reversed suppression: initial contact was a mere encounter; Young’s voluntary admission supplied probable cause to arrest and justify the search incident to arrest

Nester v. Commonwealth, 709 A.2d 879 (Pa. 1998) (standard of review on suppression appeals)
Beasley v. Commonwealth, 761 A.2d 621 (Pa. Super. 2000) (levels of police–citizen interactions)
Fuller v. Commonwealth, 940 A.2d 476 (Pa. Super. 2007) (definition of mere encounter, investigative detention, custodial detention)
Jones v. Commonwealth, 874 A.2d 108 (Pa. Super. 2005) (explanation of the three interaction levels)
Lyles v. Commonwealth, 97 A.3d 298 (Pa. 2014) (approach and questioning without restraint does not constitute a seizure)
Coleman v. Commonwealth, 19 A.3d 1111 (Pa. Super. 2011) (officer questioning—including about weapons—can be a mere encounter)
Stokes v. Commonwealth, 389 A.2d 74 (Pa. 1978) (admissions can establish probable cause to arrest)
Kondash v. Commonwealth, 808 A.2d 943 (Pa. Super. 2002) (defendant’s admission can provide probable cause to seize contraband)
Trenge v. Commonwealth, 451 A.2d 701 (Pa. Super. 1982) (search immediately prior to arrest is valid if officer had probable cause before the search)
In re D.M., 781 A.2d 1161 (Pa. 2001) (constitutional protection against unreasonable searches and seizures)