Commonwealth v. Adams, E., Aplt.
205 A.3d 1195
| Pa. | 2019Background
- At ~2:56 a.m., Officer Falconio observed a white Dodge Dart drive behind two closed businesses and park; he followed to check why the car lingered behind dark buildings.
- Falconio parked behind the car without lights or siren, called for backup, approached with a flashlight, knocked on the driver’s window, and Adams began to open his door.
- Falconio physically closed Adams’ car door and directed him to roll down the window, stating he was concerned for officer safety until backup arrived (~1 minute later).
- With backup present, Falconio spoke with Adams, smelled alcohol, observed signs of intoxication, administered field sobriety tests, arrested Adams for DUI, and obtained a consensual blood draw.
- Adams moved to suppress evidence, arguing the initial interaction was an unlawful investigative detention lacking reasonable suspicion; trial court denied suppression, convicted Adams, and Superior Court affirmed.
- The Supreme Court of Pennsylvania granted allowance, held the act of closing the car door constituted a seizure (investigative detention), and found no reasonable suspicion supported the seizure—reversing and remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument (Adams) | Defendant's Argument (Commonwealth) | Held |
|---|---|---|---|
| Whether officer conduct amounted to a seizure / investigative detention | Closing the car door and preventing exit converted the encounter into a seizure | Officer's approach and briefly closing door were non-seizure safety measures during a consensual encounter | Closing the door was a physical show of authority and constituted a seizure (not free to leave) |
| If a seizure occurred, whether officer had reasonable suspicion to justify it | No: officer had only time-and-place curiosity (car behind closed businesses at night) — insufficient specific articulable facts | Yes: lingering car in atypical location at 3 a.m. gave reasonable suspicion of criminal activity | No reasonable suspicion: officer offered only generalized concerns (time/place) akin to DeWitt; seizure was unlawful |
| Whether officer safety can justify a detention absent reasonable suspicion | Officer safety concerns cannot substitute for reasonable suspicion; safety is relevant only after a lawful stop | Officer safety justified closing the door briefly until backup arrived | Held safety concerns do not permit initiating an investigative detention without reasonable suspicion |
| Whether evidence from post-seizure investigation should be suppressed | Evidence is fruit of unlawful seizure and must be suppressed | Evidence admissible because encounter was consensual or safety-based de minimis intrusion | Held seizure unlawful and evidence should be suppressed; trial court and Superior Court decisions reversed and remanded |
Key Cases Cited
- Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (objective "free to leave" test for seizure)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigative detention requires reasonable suspicion; safety searches limited to weapons)
- Arizona v. Johnson, 555 U.S. 323 (U.S. 2009) (reaffirming that a frisk/safety action follows only a lawful stop supported by reasonable suspicion)
- Pennsylvania v. Mimms, 434 U.S. 106 (U.S. 1977) (additional intrusion of ordering exit during a lawful traffic stop is de minimis)
- Commonwealth v. DeWitt, 530 Pa. 299 (Pa. 1992) (time/place alone insufficient for reasonable suspicion; suppression required)
- United States v. Sokolow, 490 U.S. 1 (U.S. 1989) (Terry permits brief detention on reasonable suspicion)