Commonwealth v. Farnan
55 A.3d 113
| Pa. Super. Ct. | 2012Background
- Appellant John Farnan was convicted after a bench trial on August 18, 2011 of DUI-general impairment, DUI-highest rate, driving with a suspended/revoked license, and driving without a license; he was sentenced to 90 days' restrictive intermediate punishment, 18 months' probation, and fines and costs.
- The suppression issue arose from a traffic stop on September 21, 2010 in Sewickley Borough, prompted by a custody dispute between Farnan and K.L.; Farnan was identified as the driver who passed K.L.’s house when police arrived.
- Sergeant Mazza testified he had learned within the prior 30 days that Farnan’s license was suspended for a DUI-related matter, with Farnan’s license still unreinstated as of September 21, 2010 (reinstatement occurred November 19, 2010).
- The stop was justified by three reasons: (1) Farnan’s suspended license, (2) Farnan’s behavior in driving past the house where police and K.L. were present, and (3) need to investigate K.L.’s custody complaint.
- The suppression court denied Farnan’s motion; the trial court found him guilty on all counts; the issue on appeal concerns whether the stop was permissible under the reasonable suspicion standard.
- Evidence at trial included Farnan failing four field sobriety tests and a blood alcohol content of .185%; those results were not suppressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable suspicion given stale information | Farnan contends knowledge of suspension was 30 days old and stale | Mazza’s known suspension within 30 days plus totality of circumstances sustain suspicion | Stop upheld; information not stale enough to render detention unlawful |
| Whether the 30-day knowledge window appropriately supports reasonable suspicion under totality of circumstances | Total knowledge is too old to indicate ongoing violation | Totality of circumstances allows freshness within 30 days based on DUI-suspension context | 30 days deemed sufficiently fresh under the circumstances; no suppression required |
| Whether alternative grounds (suspicious driving past residence and custody dispute) independently validate the stop | Reliance on these grounds was insufficient without fresh license information | Those grounds contributed to probable reasonable suspicion in combination with license status | Overall, stop supported by reasonable suspicion; independent grounds considered but not dispositive |
Key Cases Cited
- Commonwealth v. Holmes, 14 A.3d 89 (Pa. 2011) (reasoning on totality of the circumstances and reasonable suspicion)
- Commonwealth v. Hilliar, 943 A.2d 984 (Pa. Super. 2008) (freshness of license-suspension information affects stop validity)
- Commonwealth v. Stevenson, 832 A.2d 1123 (Pa. Super. 2003) (long delays can render information stale for purposes of detention)
- Commonwealth v. Blair, 860 A.2d 567 (Pa. Super. 2004) (safety of investigative detention when reasonable suspicion exists)
- Commonwealth v. Rogers, 849 A.2d 1185 (Pa. 2004) (police may detain for investigation when reasonably suspected of criminal activity)
- Commonwealth v. McAdoo, 46 A.3d 781 (Pa. Super. 2012) (standard for reviewing suppression rulings)