Commonwealth v. Treece
161 A.3d 992
| Pa. Super. Ct. | 2017Background
- Treece was arrested for violating a PFA, taken to the police station, then transported to a hospital in handcuffs for medical treatment.
- While at the hospital Treece remained handcuffed and under police guard for a period; later officers removed his handcuffs and left the hospital, leaving him under hospital care.
- After at least an hour unguarded, Treece, assisted by a nurse, removed his IV and calmly left the hospital; he went home and then to work.
- Hospital staff notified police; officers declined to pick him up without a warrant, cancelled the original arraignment, and did not seek immediate re-arrest or involuntary commitment.
- Treece was later stopped on an unrelated traffic matter and charged with escape under 18 Pa.C.S. § 5121(a). He was convicted by a jury and sentenced; on appeal the Superior Court vacated the judgment of sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Treece was in "official detention" when he left the hospital | Commonwealth: prior arrest and transport to hospital kept him in detention for law-enforcement purposes | Treece: cuffs removed and officers left; he was unguarded and reasonably believed he was free to leave | Court: Not in official detention once officers removed cuffs and left; conviction vacated |
Key Cases Cited
- Commonwealth v. Watley, 81 A.3d 108 (Pa. Super. 2013) (sufficiency review and circumstantial evidence standard)
- Commonwealth v. Santana, 959 A.2d 450 (Pa. Super. 2008) ("any other detention for law enforcement purposes" means seizure by show of authority or force)
- Commonwealth v. Stewart, 648 A.2d 797 (Pa. Super. 1994) (officer with drawn gun and directives constituted official detention)
- Commonwealth v. Woody, 939 A.2d 359 (Pa. Super. 2007) (no detention when officer’s commands were not accompanied by restraint or control)
- Commonwealth v. Freeman, 757 A.2d 903 (Pa. 2000) (reasonable-person test; an encounter has a clear endpoint when officer tells person they are free to leave)
- Commonwealth v. Lyles, 97 A.3d 298 (Pa. 2014) (totality-of-circumstances and reasonable-person standard for seizure analysis)