HomeMy WebLinkAbout97-2080 CriminalCOMMONWEALTH
DOUGLAS E. GAST
OTN: E8629902
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 97-2080 CRIMINAL TERM
: CHARGES: (1) UNL. POS. SM. AMT. MARIJ.
(2) UNL. POS. DRUG PARA.
(3) D.U.I.
IN RE: OPINION PURSUANT TO PA. R.A.P. 1925
OLER, J., November 13, 1998.
In this criminal case, Defendant has appealed to the Superior Court from a judgment
of sentence for possession of a small amount of marijuana, unlawful possession of drug
paraphernalia, and driving under the influence.~ The sole basis for the appeal is that the
court erred in denying Defendant's pretrial motion to suppress evidence.2
The motion to suppress, as argued to this court, related to the legality of a municipal
police officer's actions outside of his municipality.3 In a statement of matters complained
of on appeal, Defendant has listed the following issues as now being pursued:
1. The arrest of the Defendant outside the jurisdiction of
the Mount Holly [Borough] police officer was illegal because it
was without probable cause and not pursuant to any lawfully or
properly prepared arrest warrant and was therefore in violation
of Defendant's constitutional rights under the Fourth and
Fourteenth amendments of the U.S. Constitution and Article I,
~ Defendant was found guilty as charged following a bench trial before the Honorable
George E. Hoffer of this court on July 1, 1998. On July 21, 1998, Defendant was sentenced
to pay a fine of $100 for possession of the marijuana, to pay a fine of $100 for possession of
the drag paraphernalia, and to pay a fine of $300 and to undergo imprisonment for a period
of not less than 30 days nor more than 23 months for driving under the influence.
2 See Defendant's Matters Complained of on Appeal, filed September 3, 1998.
3 N.T. 12, Hearing on Defendant's Motion To Suppress, February 23, 1998
(hereinafter N.T. ~).
{}8 of the Pennsylvania Constitution.
2. The mere crossing of the centerline or the right side
of the road does not constitute probable cause to indicate that
criminal activity is afoot. Commonwealth v. Whitmyer, 415 Pa.
Super. $93, 609 A.2d 809 (1992); Commonwealth v. Malone, 42
Cumb. 591 (1993).
3. The stop and arrest of the Defendant outside of the
jurisdiction of the Mount Holly Police Department City [sic]
limits was a violation of the Municipal Police Jurisdiction Act
(MPJA), 42 Pa. CSA {}8953, because there was no criminal
violation observed within the officer's primary jurisdiction.
4. In order to be an exception to the MPJA, the hot and
fresh pursuit requirement of the MPJA necessitates a finding
that the police officer had met the immediate, continuous and
uninterrupted pursuit standard and that he had met the additional
requirement of some sort of "chase", neither of which occurred.
42 Pa. CSA {}8953 (a)(2); Commonwealth v. McPeak, 708 A.2d
1263 (Pa. Super. 1998); Commonwealth v. Futchko, to 363
Criminal (Bucks County 1997) (Attached)
As will be noted hereafter, the issue of probable cause was not preserved at the
suppression hearing. In addition, a factual "stipulation" appended to Defendant's Notice of
Appeal was not presented to the suppression court.4
This opinion in support of the pretrial ruling which denied Defendant's motion to
suppress is written pursuant to Pennsylvania Rule of Appellate Procedure 1925(a).
STATEMENT OF FACTS
Shortly after 12:30 a.m. on Sunday, June 23, 1997, Officer Troy Wiser, a member of
the police department of the Borough of Mount Holly, Cumberland County, Pennsylvania,
4 This document does not appear as an item on the docket. Defendant did not direct
that the notes of testimony of the trial be transcribed and filed for purposes of his appeal, and
there is no indication that the trial court was asked to review the suppression court's ruling
on the basis of the stipulation. Cf Commonwealth v. DeMichel, 442 Pa. 553,559-60, 277
A.2d 159, 162 (1971).
2
was on duty in the borough in a marked patrol car and in full uniform? Officer Wiser
observed Defendant driving a vehicle east on a street which intersected with North Baltimore
Avenue.6 He watched Defendant make a right turn onto North Baltimore Avenue, a two-lane
roadway divided by a double-yellow line, proceeding southward.7
In executing the turn, Defendant crossed the double-yellow line and nearly struck
parked cars.g Officer Wiser began to follow the vehicle down North Baltimore Avenue?
During a course of about 1.2 miles within the borough on North Baltimore Avenue,l°
Officer Wiser observed Defendant's vehicle cross the double-yellow center line three times
and drive off the right side of the road six times.~ The vehicle crossed the borough's
boundary line and almost immediately, in a turn, trespassed by three-fourths of its width into
the opposite lane of traffic, accelerating as Defendant acted to correct its course.~2
At this point, which was about 1500 feet beyond the borough line, Officer Wiser
activated his lights and siren and, after some difficulty, succeeded in getting the vehicle
stopped.~3 Defendant was eventually charged with driving under the influence, possession
of marijuana, and possession of drug paraphernalia.
On June 13, 1998, Defendant filed a motion to suppress "all evidence seized by the
s N.T. 4-5.
6N.T. 6, 8.
7N.T. 5-6, 11.
8N.T. 5.
9Id.
lo See N.T. 8-9.
~ N.T. 6.
~2 N.T. 7.
~3 N.T. 7-8.
police," contending that "[t]he arrest of the defendant was illegal because it was without
probable cause and not pursuant to any lawful or properly prepared arrest warrant," and that
"It]he arrest of the defendant was illegal because it was made outside the jurisdiction of the
Mount Holly Police Department territorial limits." A hearing was held on Defendant's
motion by the writer of this opinion on February 23, 1998.
At the hearing, Defendant's counsel argued that suppression was warranted on the
ground that the officer had exceeded his authority under the Municipal Police Jurisdiction
Act.ia Defendant's counsel expressly disavowed any claim that the officer had lacked
probable cause to stop the vehicle? In view of Defendant's erratic and unsafe driving, a
14 Act of June 15, 1982, P.L. 512, § 4, as amended, 42 Pa. C.S. § 8953 (1998 Supp.);
N.T. 12..
~5 In this regard, the following exchange occurred between the court and Defendant's
counsel during argument on the motion:
MR. ABELN: Your Honor, I submitted to the Court for
your review, Commonwealth v. Futchko, which I've also given
a copy to the prosecution for their review. And we would ask
that this Court suppress the evidence that was taken in this case
as a violation of the Jurisdictional Act, specifically 42 Pa.
C.S.A. Section 8953(A)(2), and in conjunction with
Commonwealth v. Ma?rood and McGrady, that has been cited
in the opinion.
THE COURT: All right. You're not suggesting that
there was not probable cause to stop?
MR. ABELN: No, sir. The weaving would have given
the officer probable cause to stop him three times and six times
during the course of the time that he was observed in Mount
Holly. But instead, he continued to follow him out of Mount
Holly when he could have pulled him over, and waited until he
was outside the jurisdiction to actually culminate in what he
believed was probable cause for the arrest.
N.T. 12.
contrary position--that the stop was constitutionally defective--would have been untenable. 16
Following the hearing, the court entered this order:
AND NOW, this 23rd day of February, 1998, upon
consideration of the Defendant's Motion To Suppress Evidence,
and following a hearing held on this date, the motion is denied.
Defendant's appeal from the eventual judgment of sentence, assigning the court's
ruling as error, was filed on August 19, 1998.
The Municipal Police Jurisdiction Act provides, in pertinent part, as follows:
Any duly employed municipal police officer who is
within this Commonwealth, but beyond the territorial limits of
his primary jurisdiction, shall have the power and authority to
enforce the laws of this Commonwealth or otherwise perform
the functions of that office as if enforcing those laws or
performing those functions within the territorial limits of his
primary jurisdiction.., where the officer is in hot pursuit of any
person for any offense which was committed, or which he has
probable cause to believe was committed, within his primary
jurisdiction and for which offense the officer continues in fresh
pursuit of the person after the commission of the offense. ~?
This statute "does not fall within the class of statutes which are to be strictly construed
... and therefore, it must be liberally construed to effect its objects and to promote justice."
Commonwealth v. Fetsick, 342 Pa. Super. 264, 267, 572 A.2d 793,794 (1990). "The general
purpose of the statute is to restrict the jurisdiction of police to their own municipalities, on
the one hand, while allowing certain practical and policy exceptions to the general rule on
~6 See, e.g., Commonwealth v. Lawrentz, 453 Pa. Super. 118, 683 A.2d 303 (1986),
appeal denied 548 Pa. 645, 695 A.2d 784 (1987) (where police officer observed defendant's
vehicle weaving for a mile to a mile and a half, and vehicle crossed center line twice, legally
sufficient basis to stop for unsafe driving existed); cf. Commonwealth v. Carlson, 705 A.2d
468 (Pa. Super. Ct. 1998).
17 Act of June 15, 1982, P.L. 512, § 4, 42 Pa. C.S. § 8953(a)(2).
5
the other hand." Commonwealth v. Merchant, 385 Pa. Super. 264, 268, 560 A.2d, 796-97
(1989).
"Hot pursuit," in this context, includes "both classic 'hot pursuit' and 'fresh' or
'continuous' pursuit." Commonwealth v. Magood, 503 Pa. 169, 177, 469 A.2d 115, 119
(1983) (interpreting prior statute on "intrastate hot pursuit"). In some circumstances, an
officer's pursuit for an offense committed within his or her primary jurisdiction may occur
entirely outside of that jurisdiction. Commonwealth v. Fetsick, 392 Pa. Super. 264, 572 A.2d
793 (1990) (observation of offense within primary jurisdiction by officer located outside of
jurisdiction, and subsequent pursuit).
The Commonwealth Court has upheld the legality of a stop outside of an officer's
primary jurisdiction in the following circumstances:
[Officer] Ressler observed Licensee's erratic driving
within Marietta Borough, his own jurisdiction. He followed
Licensee who crossed the township line into East Donegal
Township and exhibited more erratic driving. Licensee was
stopped in East Donegal Township and an arrest and request for
chemical testing followed. Ressler had the authority to follow
and arrest Licensee outside his jurisdiction based on his
observations of an offense inside his jurisdiction, under 42 Pa.
C.S. § 8952(a)(2).
Commonwealth of Pennsylvania, Department of Transportation v. Park, 143 Pa. Commw.
19, 24, 598 A.2d 575, 578 (1991).
Based upon the foregoing authority, the court was of the view that in the present case
Officer Wiser's conduct in following the erratically-driven vehicle of Defendant within his
primary jurisdiction and stopping it a few hundred yards beyond the borough line was
authorized by the Municipal Police Jurisdiction Act?
~8 This case is distinguishable, in the court's view, from Commonwealth v. Futchko,
No. 2363/1997, Court of Common Pleas of Bucks County (slip op. October 23, 1997)
(William H. Rule, J.), af~d, ~ A.2d .., ~ (Pa. Super. Ct., April 14, 1998) (No. 3468
Philadelphia 1997) (memorandum opinion). In Futchko, a member of the Newtown Borough
Even if it were to be assumed that Officer Wiser exceeded his authority under the
Municipal Police Jurisdiction Act, suppression would not have been appropriate in these
circumstances. The Pennsylvania Superior Court has held that suppression is, as a general
rule, an inappropriate remedy for an unauthorized arrest made by a Pennsylvania municipal
police officer outside his or her primary jurisdiction. Commonwealth v. Saul, 346 Pa. Super.
155, 161,499 A.2d 358, 361 (1985). Stated more precisely, if the officer would have had
the power to perform the duty that he or she performed had the officer been within his or her
primary jurisdiction, and if no constitutional rights were violated,~9 suppression has been
viewed as too harsh a remedy for the impropriety. Commonwealth v. Bienstack, 449 Pa.
Super. 299, 305,673 A.2d 952, 955 (1996).
Police Department observed an incident of careless driving and speeding within his primary
jurisdiction, followed the vehicle into another jurisdiction, and stopped the vehicle in that
jurisdiction.
The officer in Futchko made a conscious decision while in his primary jurisdiction to
stop the vehicle, but chose not to do so at that time. He allowed the vehicle to leave his
primary jurisdiction without observing any further violations, and without considering
himself to be in hot pursuit of the vehicle. His purpose, as found by the suppression court,
in allowing the driver to leave the jurisdiction and to proceed for another mile was to obtain
evidence for a prosecution for an additional charge of driving under the influence--not, as
the officer had testified, to secure a safe place for the stop. Under these circumstances, the
Futchko court found as a fact that the officer "was not in 'pursuit,' hot, fresh or otherwise."
Id. at 6.
In the present case, the court did not perceive that Officer Wiser had made a conscious
decision to stop Defendant's vehicle upon his initial observation of speeding and careless
driving violations, or that he felt that he was not in pursuit of Defendant's vehicle within the
meaning of the Municipal Police Jurisdiction Act, or that the extension of the pursuit for a
few hundred yards into an adjoining township was a subterfuge to obtain enough evidence
to make an arrest for driving under the influence. These distinctions render Defendant's
position in the present case with regard to the Municipal Police Jurisdiction Act far less
compelling than that of the defendant in Futchko.
~9 See notes 15-16 supra and accompanying text.
CONCLUSION
For the foregoing reasons, it is believed that the ruling of the court denying
Defendant's pretrial motion to suppress evidence was proper.
John A. Abom, Esq.
Assistant District Attorney
Gregory B. Abeln, Esq.
Attorney for Defendant