Commonwealth v. Neal
151 A.3d 1068
| Pa. Super. Ct. | 2016Background
- On Nov. 28, 2014 the Commonwealth charged Vaughn Neal with simple possession of a controlled substance.
- At an April 10, 2015 Municipal Court suppression hearing, Neal argued officers lacked reasonable suspicion to detain/frisk him and lacked probable cause to seize and open a Bic lighter that allegedly contained crack packets.
- The Municipal Court judge denied the motion to suppress orally—"Motion to suppress denied."—but entered no findings of fact or conclusions of law.
- Neal was tried before a different Municipal Court judge, found guilty, and sentenced to six months’ probation.
- Neal filed a petition for writ of certiorari in the Court of Common Pleas challenging the suppression ruling; the common pleas court initially granted then reconsidered and denied the petition.
- The Superior Court vacated the common pleas denial and remanded because the Municipal Court failed to enter the required findings of fact and conclusions of law, preventing proper appellate review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to detain/frisk Neal after he exited a car with a history of drug activity | Neal: stop was improper—mere exit from a car formerly associated with drug activity insufficient for detention | Commonwealth: officer’s knowledge of car’s drug history supported the stop/detention | Municipal Court failed to make findings; Superior Court remanded for factual findings and legal conclusions before ruling on the merits |
| Whether officer lawfully searched a closed cigarette lighter without a warrant or exception | Neal: opening a closed container (lighter) required warrant or applicable exception; seizure/search unconstitutional | Commonwealth: evidence (packets found inside lighter) justified seizure/search under facts to be established | Same as above—remanded for Municipal Court to enter findings and conclusions to permit appellate review |
Key Cases Cited
- Commonwealth v. Coleman, 19 A.3d 1111 (Pa. 2011) (scope of appellate review of suppression rulings)
- Commonwealth v. Menezes, 871 A.2d 204 (Pa. Super. 2005) (common pleas reviews municipal court suppression records on certiorari)
- Commonwealth v. Jones, 988 A.2d 649 (Pa. 2010) (standard of review—factual findings vs. legal conclusions in suppression appeals)
- In re L.J., 79 A.3d 1073 (Pa. 2013) (review limited to suppression hearing record)
- Commonwealth v. Landis, 89 A.3d 694 (Pa. Super. 2014) (vacatur and remand when court fails to enter required findings and conclusions)
- Commonwealth v. Grundza, 819 A.2d 66 (Pa. Super. 2003) (remedy when suppression court omits findings of fact and conclusions of law)