District Attorney victory in the Superior Court will have a significant statewide impact
On Tuesday, October 18, 2016, the Dauphin County District Attorney’s Office won a significant appellate victory in the Superior Court. Attorneys from the District Attorney's Office were able to convince the Superior Court not to follow one of its own cases decided only a year ago in 2015. That case, Commonwealth v. Nguyen, 116 A.3d 657 (Pa. Super. Ct. 2015), significantly handicapped law enforcement’s ability to investigate traffic stops. Specifically, it held that police could not utilize facts learned during a valid traffic stop to justify an investigatory detention occurring after police tell a defendant that they are free to leave.
Recognizing the error in the Nguyen Court’s reasoning, the District Attorney’s Office decided to fight the issue when it arose in a Juvenile matter that same year. The result, was Tuesday’s decision In The Interest of: A.A., a Minor, No. 1931 MDA 2015 (Pa. Super. Ct. 2016). The Court, in A.A, declined to follow the Nguyen court’s decision and determined that that Court had unwittingly relied upon faulty case precedent. Instead the Court in A.A., held that “in situations where an officer ends a lawful traffic stop, but then re-initiates an investigative detention of an occupant of that vehicle, we apply the ‘totality of the circumstances’ test to assess whether the officer possessed reasonable suspicion.” Under that test, the officer’s reasonable suspicion to conduct the subsequent detention may be premised on facts gathered during the valid traffic stop. Although, the officer cannot solely rely upon the initial traffic violation to prolong the detention; they need other information supporting reasonable suspicion. Deputy District Attorneys Anthony Corby, Joe Cardinale, and Kristie Falbo argued the case on behalf of the Commonwealth.
To read the facts of the A.A. case and the Superior Court's Opinion click here: In The Interest of: A.A., a Minor, No. 1931 MDA 2015 (Pa. Super. Ct. 2016)