2007 Pa. Super. 11 - Commonwealth v. Peters’s Empirical Analysis

Citation profile

10 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(a) General rule. — 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 in the following cases: (2) 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.”

   2 later decisions quote this exact passage
   e.g. Commonwealth v. Peters · 2017 Pa. Super. 171 - Commonwealth v. Forsythe

2. “One of the principal purposes of the MPJA is to promote public safety while placing a general limitation on extraterritorial police patrols. It is in the interest of promoting public safety, therefore, that the MPJA exceptions contemplate and condone extra-territorial activity in response to specifically identified criminal behavior that occur[s] within the primary jurisdiction of the police. [Commonwealth v.] Laird, [ 797 A.2d 995, 998 (Pa.Super.2002) ]. Because of this purpose, our Supreme Court has explained that suppression of evidence is not always an appropriate remedy when there has been a violation of the MPJA. In Commonwealth v. O’Shea, 523 Pa. 384 , 567 A.2d 1023 (Pa.1989), the court stated: In Commonwealth v. Mason, 507 Pa. 396 , 490 A.2d 421 (1985), we held that suppression of evidence was an inappropriate remedy for a violation of the Rules of Criminal Procedure relating to the issuance and execution of a search warrant outside of a police officer’s primary jurisdiction where said violation did not implicate fundamental, constitutional concerns, was not conducted in bad faith or did not substantially prejudice the accused in the sense that the search would not otherwise have occurred or would not have been as intrusive. Automatic exclusion of evidence obtained by searches accompanied by relatively minor infractions of the rules of criminal procedure would be a remedy out of all proportion to the violation, or to the benefits gained to the end of obtaining justice”

   1 later decision quote this exact passage
   e.g. 2008 Pa. Super. 22 - Commonwealth v. Hilliar

3. “The courts of this Commonwealth have consistently held that in applying the MPJA in a manner that effectuates its purpose, we should construe its provisions liberally. This Act is not among those statutes which must be strictly construed under the rules of statutory construction, but instead is subject to liberal construction to effectuate its objectives and to promote justice. Commonwealth v. McHugh, 413 Pa.Super. 572 , 605 A.2d 1265 (1992). Specifically, one of the principle objectives to be obtained by this Act is to promote public safety while maintaining jurisdictional police lines. Commonwealth v. Merchant, 528 Pa. 161 , 595 A.2d 1135 (1991). However, as our Supreme Court stated in Merchant , “the General Assembly recognized that constructing impenetrable jurisdictional walls benefited only the criminals hidden in their shadows.” Id. at 169 , 595 A.2d at 1139 . Commonwealth v. Eisenfelder, 444 Pa.Super. 435 , 664 A.2d 151, 153 (1995).”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Cole