Commonwealth v. Cauley
10 A.3d 321
| Pa. Super. Ct. | 2010Background
- Cauley was convicted of Driving Under the Influence of Alcohol (75 Pa.C.S. § 3802(c)) after an incident in Trafford Borough, Westmoreland County on January 11, 2009.
- Officer Bell parked, Cauley drove up the street, parked 20–30 feet away, and Cauley immediately approached the officer asking why he was there.
- Bell smelled a strong odor of alcohol and observed Cauley’s bloodshot eyes, prompting requests to perform field sobriety tests which Cauley accepted and failed.
- Cauley admitted drinking that evening; a breathalyzer yielded a BAC of 0.199%.
- A pretrial motion to suppress was denied; the case proceeded to a non-jury trial with stipulated transcripts and BAC reading; Cauley was sentenced to five years’ intermediate punishment with home electronic monitoring.
- On appeal, Cauley contends Bell lacked reasonable suspicion to stop him or to administer sobriety tests; the court held a citizen-initiated encounter can evolve into a detention if indicia of intoxication are observed and driving occurred just before the encounter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was reasonable suspicion to detain for sobriety testing | Cauley asserts Bell had no basis to suspect DUI as he saw no traffic violation and Cauley had no remarkable conduct | The Commonwealth contends Bell observed indicators of intoxication and Cauley had driven to the scene just prior, establishing reasonable suspicion | Yes; Bell had reasonable suspicion based on odor, bloodshot eyes, and prior driving to the scene |
Key Cases Cited
- Commonwealth v. Bomar, 573 Pa. 426, 826 A.2d 831 (2003) (standard for reviewing suppression rulings; factual findings controlling if supported by the record)
- Commonwealth v. Sands, 887 A.2d 261 (Pa.Super.2005) (three levels of police-citizen interaction; reasonable suspicion required for investigative detention)
- Commonwealth v. Hill, 874 A.2d 1214 (Pa.Super.2005) (determines levels of encounter; standard for detentions and seizures)
- Commonwealth v. Beasley, 761 A.2d 621 (Pa.Super.2000) (mere encounter may not require reasonable suspicion; cautions on escalation)
- Commonwealth v. Peters, 434 Pa.Super. 268, 642 A.2d 1126 (1994) (example of non-coercive inquiry; restraint implications)
- Commonwealth v. Smith, 904 A.2d 30 (Pa.Super.2006) (investigative detention requires reasonable suspicion; duration limited to dispel suspicion)
- Commonwealth v. LaMonte, 859 A.2d 495 (Pa.Super.2004) (premised on reasonable suspicion; duration of detention reasonable to confirm/dispel)
- Commonwealth v. Angel, 946 A.2d 115 (Pa.Super.2008) (classic signs of intoxication include odor and glassy eyes)
- Commonwealth v. Smith, 904 A.2d 30 (Pa.Super.2006) (reiterates standards for testing and detention)