Commonwealth v. Parker, 161 A.3d 357

Police conducted a buy‑walk drug investigation; on June 24, 2014 Officer Hagy observed a seller known as “Heart” (black male, dreadlocks, orange shirt, camo shorts, unique gait) sell drugs to an undercover buyer.
On August 1, 2014 Officer Hagy, parked nearby, later told Officer Boas that he had seen the same individual at a McDonald’s parking lot and identified him as the prior seller.
Officers Boas and Mease (on bicycles) intercepted the man on the sidewalk at night, blocked his path with their bikes, and told him—falsely—that he was part of a disturbance at McDonald’s as a pretext to obtain identification.
The man (Parker) provided name, DOB, address, phone number and SSN; that information was later used to link him to drug sales on June 24 and July 17, 2014.
Parker moved to suppress the identification obtained on August 1, 2014; the suppression court denied the motion, a jury convicted him of PWID, criminal use of a communication facility, and conspiracy, and the Superior Court reviewed the suppression ruling on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether police conduct on Aug 1, 2014 amounted to an investigative detention requiring reasonable suspicion	Commonwealth: officers merely requested ID during a street encounter; no seizure occurred and no reasonable‑suspicion requirement was triggered	Parker: presence of two officers, bikes blocking path, and false allegation of involvement in a disturbance created a show of authority—this was a seizure requiring reasonable suspicion, which officers lacked	Court held it was an investigative detention; officers’ conduct would make a reasonable person feel not free to leave, and they lacked reasonable suspicion, so suppression should have been granted

Commonwealth v. Jones, 121 A.3d 524 (Pa. Super. 2015) (standard of review for suppression appeals)
Commonwealth v. Matos, 672 A.2d 769 (Pa. 1996) (adopting objective Mendenhall/Jones test to determine seizure vs. mere encounter)
United States v. Mendenhall, 446 U.S. 544 (U.S. 1980) (reasonable‑person test for seizure under the Fourth Amendment)
Commonwealth v. Martin, 705 A.2d 887 (Pa. Super. 1997) (combination of multiple officers’ presence and indication of suspicion transforms contact into a seizure)
Commonwealth v. Au, 42 A.3d 1002 (Pa. 2012) (officer’s request for ID in a noncoercive encounter does not automatically constitute a seizure)
Commonwealth v. Lyles, 97 A.3d 298 (Pa. 2014) (objective seizure analysis; officer’s subjective belief immaterial)