Commonwealth v. Runyan
160 A.3d 831
| Pa. Super. Ct. | 2017Background
- At 12:32 a.m. officers in uniform approached a parked sedan near a bar in a high‑crime area and smelled burnt marijuana emanating from the vehicle.
- Officer Gatewood shined a flashlight into the car and observed a small baggie that appeared to be marijuana on the backseat floor.
- Officers asked occupants to exit; the driver attempted to move and exit the vehicle; all four occupants were handcuffed and detained behind the car.
- Officer Gatewood searched the vehicle without a warrant, seized the visible baggie, removed several purses from the back seat, and searched them outside the vehicle without consent.
- Appellee Runyan’s purse contained a spoon, syringe, and suspected crack pipe; another purse contained syringes and a spoon. Runyan was arrested and charged with possession of drug paraphernalia. The suppression court granted Runyan’s motion and suppressed the purse evidence.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Runyan) | Held |
|---|---|---|---|
| Whether officers had probable cause to search the vehicle and containers inside it | Probable cause existed from smell of burnt marijuana and observed baggie; vehicle search may include containers capable of concealing contraband | Search of Runyan’s purse was not incident to arrest and required separate justification; Shiflet bars warrantless purse searches here | Court held there was probable cause to search the car; under Gary/Houghton/In re I.M.S. containers within the car (including purses) may be searched when vehicle probable cause exists |
| Whether the purse search was justified as search‑incident‑to‑arrest | Commonwealth: purse search was not claimed as incident to arrest; justification rests on automobile exception | Runyan: suppression court relied on search‑incident‑to‑arrest doctrine and Shiflet to exclude purse search | Appellate court rejected Shiflet’s application here and remanded, holding automobile probable cause governs container searches |
Key Cases Cited
- Commonwealth v. Gary, 625 Pa. 183, 91 A.3d 102 (Pa. 2014) (Pennsylvania aligns automobile search law with federal Fourth Amendment; probable cause alone permits warrantless vehicle searches)
- Wyoming v. Houghton, 526 U.S. 295 (U.S. 1999) (if probable cause justifies car search, police may search containers in the car that could conceal the object of the search)
- Commonwealth v. Shiflet, 543 Pa. 164, 670 A.2d 128 (Pa. 1996) (search of a passenger’s purse was not justified as incident to another occupant’s arrest where the search was too attenuated)
- In re I.M.S., 124 A.3d 311 (Pa. Super. Ct. 2016) (applying Gary and Houghton to hold probable cause to search a vehicle permits search of passenger’s belongings capable of concealing contraband)