Commonwealth v. Holmes
14 A.3d 89
| Pa. | 2011Background
- On December 6, 2006, Officer Trotta observed a black vehicle on Route 315 with objects hanging from the rearview mirror that allegedly obstructed the driver’s view.
- Trotta, parked at a Sunoco, activated lights and stopped the vehicle after it traveled a short distance toward the Turnpike entrance.
- Holmes provided his name but indicated his license was suspended and he had no proof of ownership; a pat-down revealed a bulge later identified as cash.
- A canine sniff occurred after consent (disputed by Holmes); the dog alerted and drugs and other contraband were found in the vehicle and Holmes’ sock.
- Holmes was charged with PWID and weapons offenses; no § 4524(c) violation was charged at trial; suppression was denied, but appeal led to a Superior Court reversal for a new trial on reasonable-suspicion grounds.
- The Pennsylvania Supreme Court granted review to address whether the stop was supported by reasonable suspicion under § 6308(b) and § 4524(c).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Trotta had reasonable suspicion to stop for weather § 4524(c). | Holmes argues no articulable facts showed material obstruction. | Commonwealth contends Trotta observed obstructing objects and thus had reasonable suspicion. | Stop invalid; no sufficient articulable facts showed a material obstruction. |
| Whether the Superior Court properly vacated Holmes’ sentence based on the suppression ruling. | Commonwealth seeks reinstatement of conviction. | Holmes argues suppression error warrants new trial. | Affirmed; remanded for new trial. |
Key Cases Cited
- Commonwealth v. Brown, 996 A.2d 473 (Pa. 2010) (defines reasonable suspicion under current § 6308(b))
- Commonwealth v. Chase, 960 A.2d 108 (Pa. 2008) (articulable facts required for vehicle stops under § 6308(b))
- Commonwealth v. Cook, 735 A.2d 673 (Pa. 1999) (requires specific facts and inferences for reasonable suspicion)
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes specific and articulable facts standard for detentions)
- Commonwealth v. Swanger, 307 A.2d 875 (Pa. 1973) (limits police discretion in automobile stops)
- Commonwealth v. Murray, 331 A.2d 414 (Pa. 1975) (limits reliance on hunches in vehicle stops)
- Commonwealth v. Felty, 662 A.2d 1102 (Pa. Super. 1995) (early § 4524(c) obstruction considerations (super. court))
- Commonwealth v. Benton, 655 A.2d 1030 (Pa. Super. 1995) (obstruction and stop analysis under § 4524(c))