Commonwealth v. Walls
53 A.3d 889
| Pa. Super. Ct. | 2012Background
- Officer Messer received an anonymous tip describing a man with a gun near 13th St and Allegheny Ave; Walls matched the description and was observed half a block from the location.
- Walls fled southbound when approached by Messer, prompting a pursuit around the block and a radio alert to other officers.
- Officer Sitek observed Walls discard an object during a pursuit and chased him into an alley where Walls surrendered.
- Sitek recovered a loaded Lama handgun with eight live rounds near 3131 13th Street.
- Walls was charged with three counts under the Uniform Firearms Act; he moved to suppress the handgun as the product of an unlawful detention.
- The suppression court granted Walls’ motion, and the Commonwealth appealed seeking reversal and remand for proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Messer have reasonable suspicion to detain Walls? | Commonwealth: yes, flight plus matching description supported suspicion. | Walls: no independent corroboration; description alone insufficient. | Yes; reasonable suspicion supported by totality of circumstances. |
Key Cases Cited
- In re D.M., 560 Pa. 166, 743 A.2d 422 (Pa. 1999) (flight adds to reasonable suspicion after tip)
- Wardlow, 526 U.S. 119 (U.S. Supreme Court 2000) (unprovoked flight in a high-crime area relevant to Terry analysis)
- United States v. Arvizu, 534 U.S. 266, 122 S. Ct. 744 (U.S. Supreme Court 2002) (totality-of-the-circumstances framework)
- Commonwealth v. Daniels, 999 A.2d 590 (Pa. Super. 2010) (three levels of police-citizen intrusion; investigative detention requires reasonable suspicion)
- Commonwealth v. Gutierrez, 36 A.3d 1104 (Pa. Super. 2012) (applies totality-of-the-circumstances approach to reasonable suspicion)