Commonwealth v. Haines
166 A.3d 449
Pa. Super. Ct.2017Background
- Around 4:00 a.m. police responded to a single-vehicle crash: a 2012 Jeep off the road with deployed airbags, damaged windows, no occupant present, and a tow was requested.
- Trooper Mason waited at the scene with lights on; about ten minutes later he observed another car approach, stop for 10–15 seconds near the crash site, then continue past.
- Trooper Mason ran the passing car’s plate, learned it was registered to a Samuel Haines (same surname as the crashed vehicle’s owner, Douglas Haines), and stopped the car about one-half mile north of the scene.
- The trooper identified Douglas Haines as the front-seat passenger by matching the driver’s license photo from the crashed Jeep’s registration and detected the odor of alcohol; Haines failed field sobriety tests and was arrested. A blood draw at 5:15 a.m. showed BAC .244%.
- Haines moved to suppress evidence from the stop and later moved in arrest of judgment post‑verdict relying on Birchfield; suppression denied, bench trial convicted Haines of DUI—highest rate (§3802(c)), sentenced, and appealed.
Issues
| Issue | Haines' Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Validity of stop of the second vehicle | Stop was unconstitutional; mere coincidence of shared surname cannot justify stop; Andersen controls | Trooper had reasonable suspicion to investigate a possible failure to report crash under 75 Pa.C.S. §3746(a)(2): damaged unattended vehicle, car stopped nearby, shared surname, proximate location/time | Stop was lawful under reasonable‑suspicion standard; totality supported brief investigatory stop for possible §3746 violation |
| Level of suspicion required for this stop | Probable cause required because stop targeted a vehicle not observed committing an offense | Because officer was investigating whether an accident-reporting offense occurred and evidence might be in another vehicle, a Terry‑style stop (reasonable suspicion) was sufficient | Reasonable suspicion sufficed; section 6308(b) and precedent allow investigatory stops when a stop may yield information relevant to the suspected violation |
| Applicability of Andersen (owner not necessarily driver) | Andersen precludes stopping a vehicle merely because owner has relevant status (e.g., suspended license) | Andersen is distinguishable — here officer had additional articulable facts linking the passing vehicle to the crash | Andersen distinguished; the combination of facts supported reasonable suspicion |
| Suppression of blood draw under Birchfield v. North Dakota | Birchfield requires warrant for blood draws; no warrant here, so blood evidence must be suppressed and judgment arrested | Birchfield permits warrantless blood draws if valid consent; record lacks sufficient evidence on voluntariness of consent; procedural default (issue not raised pretrial) | Trial court did not grant arrest of judgment; issue is best resolved via PCRA where a full record on consent can be developed; Birchfield does not automatically invalidate the blood result without a developed record |
Key Cases Cited
- Commonwealth v. Ibrahim, 127 A.3d 819 (Pa. Super. 2015) (distinguishes stops requiring probable cause versus reasonable suspicion)
- Commonwealth v. Feczko, 10 A.3d 1285 (Pa. Super. 2010) (section 6308(b) is conceptually equivalent to Terry investigatory stops)
- Commonwealth v. Chase, 960 A.2d 108 (Pa. 2008) (vehicle stops for noninvestigatable offenses require probable cause)
- Commonwealth v. Salter, 121 A.3d 987 (Pa. Super. 2015) (analysis comparing violations needing probable cause versus those investigatable by stop)
- Birchfield v. North Dakota, 136 S. Ct. 2160 (U.S. 2016) (warrant required for nonconsensual blood draws in DUI context; consent remains a valid exception)
- Commonwealth v. Andersen, 753 A.2d 1289 (Pa. Super. 2000) (officer lacks reasonable suspicion to stop vehicle based solely on ownership or suspended status of registered owner)
- Commonwealth v. Zhahir, 751 A.2d 1153 (Pa. Super. 2000) (reasonable suspicion requires a lesser showing than probable cause)