Commonwealth v. Barnes
14 A.3d 128
| Pa. Super. Ct. | 2011Background
- Officer stops a silver Pontiac for air fresheners blocking view on West Edwin Street; stop framed as 75 Pa.C.S.A. § 4524(c).
- In high-crime area, officer asks occupants for identification; passenger gives false name and DOB multiple times.
- Computer checks for Troy Anderson with DOBs yield no record; officer informs passenger he is the subject of an official investigation.
- Passenger is arrested; a glass bottle with suspected drug residue is found during search; passenger later identified as Barnes.
- Barnes is charged with false identification to law enforcement under 18 Pa.C.S.A. § 4914 and drug paraphernalia.
- Judge grants habeas relief and dismisses the false identification charge; Commonwealth appeals the dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 4914 requires an official investigation of a violation of law to apply | Barnes argues official-investigation element satisfied by any investigation of false ID. | Barnes asserts no violation of law was investigated when false-ID provided. | § 4914 requires investigation of a violation of law; not satisfied here. |
| Whether passenger becomes part of the investigation in a traffic stop in a high crime area | Commonwealth contends passenger becomes subject to official investigation during stop. | Barnes argues no official investigation existed at request for ID. | Passenger not under official investigation for a violation of law at the time of false ID. |
| Whether the trial court properly granted habeas relief by dismissing the charge | Commonwealth maintains charge should proceed given applicable facts. | Barnes contends lack of official investigation defeats § 4914 applicability. | Habeas relief affirmed; charge dismissed. |
Key Cases Cited
- Commonwealth v. James, 863 A.2d 1179 (Pa. Super. 2004) (probable-cause standard for prima facie cases in appellate review)
- Commonwealth v. Beattie, 601 A.2d 297 (Pa. Super. 1991) (mere encounter and police authority limits; involvement of questions)
- Commonwealth v. Polo, 759 A.2d 372 (Pa. 2000) (Fourth Amendment and investigative stops; standards for encounters)