Pennsylvania v. Lyles

In 2009, two officers on patrol in a marked police vehicle saw appellant and another male sitting on the steps of a vacant building in south Philadelphia. The officers approached the men to question their reason for loitering there, as a large number of burglaries had been reported in the area. Appellant Haleem Lyles stated his grandmother lived on the block. One officer asked for appellant’s identification, which appellant gave him. When the officer began writing down the identification information, he saw appellant place his hand in his right pocket and turn his right side away from the officer’s view; the officer told appellant to stop reaching and remove his hand. Concerned appellant might be reaching for a concealed weapon, the officer instructed him to remove his hand a second time. When appellant reached into the pocket a third time, the officer placed appellant against the wall of the building to conduct a safety frisk for weapons. Appellant once again put his hand in the pocket, so the officer forcibly removed it, and a plastic bag containing blue packets filled with crack cocaine became visible. The officer handcuffed appellant and seized the plastic bag. The officer then searched appellant and discovered a bag containing marijuana in appellant’s left pocket. Appellant was charged with possession with intent to deliver a controlled substance and possession of a controlled substance. Appellant filed a motion to suppress the drugs, which the trial court granted. The Supreme Court granted review to consider whether the Superior Court properly reversed the trial court’s suppression of evidence, which was based on a finding that an officer’s request for identification elevated an encounter to an investigative detention unsupported by reasonable suspicion. Finding no reversible error, the Supreme Court affirmed that reversal. View "Pennsylvania v. Lyles" on Justia Law