Commonwealth v. Peterson, 17 A.3d 935

Appellee and six others stood at a street corner after midnight in a high-crime Sharon, Pennsylvania area; six fled as a marked police cruiser approached.
Officer Albanese initially believed Appellee might be the victim of a crime and asked if he had been robbed; Appellee denied and explained the bag contained tools.
The officer asked for Appellee's name; after a brief exchange, Appellee provided it; the officer learned of an outstanding warrant for driving with a suspended license and arrested him.
A search incident to arrest uncovered a small amount of marijuana in a baggie, which formed the basis for the drug paraphernalia charge.
Appellee moved to suppress the evidence contending unlawful detention lacking reasonable suspicion and that the seizure was the fruit of that detention; the suppression court agreed.
The Superior Court affirmed, holding the initial detention lacked reasonable suspicion, and the evidence was suppressed under Hudson because the stop was unlawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was reasonable suspicion to detain	Peterson	Peterson	Detention not supported by reasonable suspicion
Whether evidence seized incident to arrest after an outstanding warrant is suppressible when detention was unlawful	Peterson	Peterson	Evidence suppressed; Hudson controlling

Commonwealth v. Davis, 421 A.2d 179 (Pa. 1980) (standard for reviewing suppression orders)
Commonwealth v. Bomar, 826 A.2d 831 (Pa. 2003) (limits on appellate review of suppression rulings)
Commonwealth v. Nester, 709 A.2d 879 (Pa. 1998) (legal conclusions on suppression reviewed de novo)
Commonwealth v. Hudson, 995 A.2d 1253 (Pa.Super.2010) (unlawful detention defeats admissibility of intervening evidence)
Commonwealth v. Howard, 659 A.2d 1018 (Pa.Super.1995) (identity evidence from detention not always suppressible)
Commonwealth v. Garvin, 293 A.2d 33 (Pa.1972) (unlawful arrest does not automatically taint later identifications)