Commonwealth v. Gutierrez, 36 A.3d 1104

In Sept. 2009, a confidential informant told Officer Liciardello that a Hispanic male driving a white Chevrolet on Bristol Street would be on the 400 block between 1:30–2:00 PM with heroin.
The informant provided his name and address; reliability had not been tested and the address not verified.
Officer Liciardello and the informant went to the 400 block; Gutierrez was seen driving a white Chevrolet around 1:45 PM; the informant identified Gutierrez as the suspect.
Gutierrez was ordered to stop; he tried to back up and collided with an unmarked police car.
Officer Spicer patted Gutierrez down and recovered an object containing 106 grams of heroin after Gutierrez said he was “in a lot of trouble.”
The trial court granted Gutierrez’s motion to suppress; the Commonwealth appealed arguing the stop had reasonable suspicion; the court reversed the suppression order and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by reasonable suspicion	Commonwealth argues totality shows reasonable suspicion	Gutierrez contends lack of reliable, corroborated information undermines suspicion	Yes; the stop was supported by reasonable suspicion

Commonwealth v. Holmes, 14 A.3d 89 (Pa. 2011) (Terry-based scrutiny; objective evaluation of intrusion)
Alabama v. White, 496 U.S. 325 (U.S. 1990) (predictive information with reliability when informant corroborated)
Commonwealth v. Griffin, 954 A.2d 648 (Pa. Super. 2008) (informant reliability strengthened by predictive corroboration)
Commonwealth v. Hayward, 756 A.2d 23 (Pa. Super. 2000) (identified citizen reports presumed trustworthy absent special circumstances)
Commonwealth v. Henry, 943 A.2d 967 (Pa. Super. 2008) (standard for reviewing suppression rulings; plenary as to legal conclusions)