Commonwealth v. Singleton
169 A.3d 79
Pa. Super. Ct.2017Background
- At ~12:25 a.m. in a high‑narcotics, high‑robbery area near a train terminal, Officers Laseter and Corn observed Singleton wearing a hooded sweatshirt with his hand in his pocket and a heavy object in that pocket.
- As officers approached, Singleton sat on a ledge, pulled a black bag from his sweatshirt and placed it behind him. Officers believed the bag might conceal a weapon.
- Officer Laseter looked around/behind Singleton and, without opening or manipulating the bag, saw small jars with red syrup through an opening; she recognized codeine syrup packaging.
- Officers arrested Singleton for suspected possession with intent to deliver (PWID); a search incident to arrest yielded 36 bags of heroin and 29 bags of marijuana.
- Singleton moved to suppress; the trial court denied the motion. He entered a conditional guilty plea reserving the right to appeal the suppression denial, was sentenced, and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers’ approach/questioning and their viewing of the bag constituted a seizure requiring reasonable suspicion | Commonwealth: officers’ observation and viewing were lawful; seeing contraband provided probable cause to arrest | Singleton: encounter escalated to an investigative detention (seizure) requiring reasonable suspicion, and the officers impermissibly manipulated/viewed the bag | Court: interaction remained a mere encounter; officer could view contents without manipulating the bag, giving probable cause to arrest and conduct search incident to arrest |
| Whether conditional plea waived right to appeal suppression denial | Commonwealth: plea waivers generally preclude nonjurisdictional challenges | Singleton: reserved right to appeal suppression in conditional plea | Court: although plea waivers typically bar collateral claims, court reached merits because the trial court accepted the conditional reservation and Commonwealth did not object |
Key Cases Cited
- Commonwealth v. Andrews, 158 A.3d 1260 (Pa. Super. 2017) (guilty plea waives nonjurisdictional defects)
- Commonwealth v. Jones, 929 A.2d 205 (Pa. 2007) (same principle on plea waivers)
- Commonwealth v. Woodard, 129 A.3d 480 (Pa. 2015) (standard of review for suppression rulings)
- Commonwealth v. Poplawski, 130 A.3d 697 (Pa. 2015) (scope of review limited to suppression hearing and Commonwealth evidence)
- Commonwealth v. Lyles, 97 A.3d 298 (Pa. 2014) (Fourth Amendment and seizure analysis; totality of circumstances test)
- Hiibel v. Sixth Judicial District Court of Nevada, 542 U.S. 177 (2004) (officers may request identification; mere questioning in public not a seizure)