2013 Pa. Super. 3 - Commonwealth v. Walton’s Empirical Analysis

Citation profile

5 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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In Walton , this Court held that the trial court erred in concluding that Officer Bridges had reasonable suspicion that [the a]ppellant was involved in criminal activity allowing an investigative detention. At the suppression hearing, Officer Bridges testified that he “saw a white male and female in the parking lot kind of walking around, pacing back and forth,” and that “[t]hey were on and off their cell phone several times looking around.” Officer Bridges stated that this conduct “looked kind of suspicious to [him].” He explained that based on his experience, he knew “that’s how a lot people will meet with drug dealers or drug dealers themselves will stand in a parking lot to meet them.” When Appellant’s vehicle pulled up to the couple in the parking lot and “they started talking to each other” Officer Bridges stated, “it looked like some type of deal was going to go down.” Testimony indicated that Officer Bridges was in a marked police car across the street from the parking lot at 1:51 p.m. and there was no indication that this was a high crime or drug intensive neighborhood. The record thus reflects insufficient evidence to justify an “investigative stop.” Without more, Officer Bridges’ observations are consistent with innocent activity and nothing more than a hunch a drug transaction was to transpire.”

   1 later decision quote this exact passage
   e.g. 2014 Pa. Super. 106 - Commonwealth v. Thompson

2. “Police may engage in a mere encounter absent any suspicion of criminal activity, and the citizen is not required to stop or to respond. If the police action becomes too intrusive, a mere encounter may escalate into an investigatory stop or a seizure. If the interaction rises to the level of an investigative detention, the police must possess reasonable suspicion that criminal activity is afoot, and the citizen is subjected to a stop and a period of detention. Probable cause must support a custodial interrogation or an arrest.”

   1 later decision quote this exact passage
   e.g. 2014 Pa. Super. 106 - Commonwealth v. Thompson