Commonwealth v. Ranson
103 A.3d 73
| Pa. Super. Ct. | 2014Background
- At ~3:30 a.m., Detective Curry and two uniformed officers were staffing an off-duty security detail at the Serenity Club, an after‑hours venue in a high‑crime zone with a history of violence and parolee patrons.
- A club patron who frequented the club weekly approached Detective Curry, pointed to Appellant across the street (~75 feet away), and said the man (wearing a black hoodie, black jeans, long beard) had a firearm.
- The three officers approached Appellant; as they neared, Appellant put his hands in his hoodie pocket and began to walk away. Officers ordered him to stop; he initially continued walking and only stopped after about 50 feet.
- When ordered to remove his hands, Detective Curry observed an imprint of a gun through the sweatshirt; a search revealed an operational .45 Taurus in Appellant’s front hoodie pocket.
- Appellant moved to suppress the firearm, arguing the stop lacked reasonable suspicion; the suppression court denied the motion, the trial court convicted him of receiving stolen property and related firearms offenses, and Appellant appealed.
Issues
| Issue | Ranson's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to effect an investigative stop | The stop was based on an anonymous/vague tip and therefore lacked reasonable suspicion | Tipster was a regular patron (in‑person tip with specific description), area/club high‑crime, plus Appellant’s evasive conduct justified the stop | The stop was lawful: the totality of circumstances (reliable in‑person tip, high‑crime location, and evasive behavior) supplied reasonable suspicion |
Key Cases Cited
- Commonwealth v. Jones, 605 Pa. 188, 988 A.2d 649 (Pa. 2010) (standard of review for suppression denials; appellate scope limited to suppression‑hearing record)
- Commonwealth v. Foglia, 979 A.2d 357 (Pa. Super. 2009) (anonymous tip + matching description + evasive conduct in high‑crime area can support investigative detention)
- Commonwealth v. Williams, 980 A.2d 667 (Pa. Super. 2009) (in‑person tipster pointing and officer’s opportunity to assess demeanor adds weight compared to anonymous calls)
- Commonwealth v. Hayward, 756 A.2d 23 (Pa. Super. 2000) (vague in‑person tip from unknown passerby insufficient to establish reasonable suspicion)
- Commonwealth v. Hawkins, 692 A.2d 1068 (Pa. 1997) (anonymous phone tip giving only general description insufficient for stop)
- Commonwealth v. Jackson, 698 A.2d 571 (Pa. 1997) (anonymous tip with only jacket description insufficient)
- Commonwealth v. Zhahir, 751 A.2d 1158 (Pa. 2000) (anonymous tip + matching description + suspicious conduct in high‑crime area can support detention)
- Navarette v. California, 134 S. Ct. 1683 (U.S. 2014) (911 calls bear indicia of reliability and may supply reasonable suspicion under certain circumstances)