Commonwealth v. Stilo, 138 A.3d 33

On November 13, 2013, police set up surveillance at a Philadelphia residence after receiving a narcotics complaint tied to the address and learned the owner had prior drug arrests.
At about 3:00 p.m., Anthony Stilo arrived as a passenger in a white Ford Explorer, entered the basement-converted residence for ~3 minutes, then exited.
A short time later a second male arrived, entered briefly, and both men departed within moments of one another; officers followed and stopped Stilo’s vehicle.
Officer Cleaver asked Stilo to produce identification; Stilo handed over a Ziploc bag containing marijuana and was arrested. A subsequent search found pills (Ativan and Oxycodone) on Stilo.
Stilo moved to suppress the physical evidence, arguing the stop lacked reasonable suspicion; the municipal court denied the motion, he was convicted of possession, the common pleas court denied certiorari, and the Superior Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether police had reasonable suspicion to conduct an investigative stop	Police contends the narcotics complaint, prior nexus of the residence to drugs, and brief, repeated in-and-out visits by visitors justified an investigative stop	Stilo argues officers observed only innocuous behavior (short visits, no observed transaction or furtive acts), too few corroborating facts, and mere coincidence could explain conduct	Court held there was reasonable suspicion based on the totality of circumstances and the officer's training/experience; suppression denial affirmed

Commonwealth v. Jones, 605 Pa. 188, 988 A.2d 649 (Pa. 2010) (standard of review for suppression rulings)
Commonwealth v. Foglia, 979 A.2d 357 (Pa. Super. 2009) (articulates reasonable suspicion/totality-of-circumstances test for investigative detentions)
Commonwealth v. Myers, 728 A.2d 960 (Pa. Super. 1999) (brief entries and exits from suspected drug house can supply reasonable suspicion)
Commonwealth v. Patterson, 591 A.2d 1075 (Pa. Super. 1991) (multiple suspicious entries into suspected crack house supported stop)
Commonwealth v. Woods, 590 A.2d 1311 (Pa. Super. 1991) (lack of more persuasive corroboration does not automatically defeat reasonable suspicion derived from police observations)
Commonwealth v. Carter, 105 A.3d 765 (Pa. Super. 2014) (suppression court must consider totality of circumstances and give weight to officer inferences)
Commonwealth v. Ranson, 103 A.3d 73 (Pa. Super. 2014) (reiterating Foglia principles regarding reasonable suspicion)