Commonwealth v. Snyder, 60 A.3d 165

Detective Couch learned of a homicide at Valley Terrace and invited three Valley Terrace security guards, including Snyder, to a confidential December 29, 2010 meeting to discuss the investigation.
During that meeting, Couch contemplated obtaining search warrants for Valley Terrace residences, including Henderson's, and advised attendees that discussions were confidential.
Snyder, employed as a security guard for about three months, was discharged on January 1, 2011 after a verbal altercation with his supervisors.
On January 1, 2011, Snyder informally told Henderson that the police would execute warrants at Henderson’s apartment and other Valley Terrace residences, leading Henderson to spread the information to others.
The next day Henderson informed supervisors of the disclosure; the police interviewed involved witnesses and then charged Snyder with obstructing the administration of law under 18 Pa.C.S.A. § 5101.
At trial, Snyder moved to suppress the statements made to Detective Couch, which the trial court denied; a jury convicted Snyder, and he was sentenced to one year of probation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Snyder's pre-Miranda statements should have been suppressed	Snyder asserts custodial interrogation occurred; Miranda warnings were required before questioning.	Commonwealth contends no interrogation occurred pre-Miranda, so warnings were not required.	Miranda warnings required; admission was error, but harmless.
Whether the evidence supports Snyder’s conviction under § 5101	Snyder argues there was no physical interference or breach of official duty; actions were verbal and not official.	Commonwealth argues Snyder’s conduct constituted physical interference or breach of official duty.	Evidence supports conviction for physical interference; breach of official duty not proven; otherwise harmless error.

Commonwealth v. DeJesus, 787 A.2d 394 (Pa. 2001) (interrogation before Miranda can trigger suppression; warnings required when conduct reasonably elicits statements)
Commonwealth v. Gaul, 912 A.2d 252 (Pa. Super. 2006) (linchpin: police knowledge and conduct can render encounter an interrogation)
Commonwealth v. Umstead, 916 A.2d 1146 (Pa. Super. 2007) (interrogation defined; when interrogation is present absent warnings)
Commonwealth v. Reppert, 814 A.2d 1196 (Pa. Super. 2002) (suppression standards; factual findings control legal conclusions)
Commonwealth v. Henry, 599 A.2d 1321 (Pa. Super. 1991) (harmless error doctrine for coerced confessions when overwhelming evidence)
Commonwealth v. Trolene, 397 A.2d 1200 (Pa. Super. 1979) (intentional yet unsuccessful attempts to influence the administration of law constitute § 5101 obstruction)
Commonwealth v. Scarpone, 634 A.2d 1109 (Pa. 1993) (no requirement of physical interference with officers' duties for § 5101)
Commonwealth v. Mastrangelo, 414 A.2d 54 (Pa. 1980) (conduct that frightens an officer can support § 5101)