Com. v. Anderson, G.

CourtSuperior Court of Pennsylvania
DecidedOctober 10, 2025
Docket1062 EDA 2022
StatusUnpublished

This text of Com. v. Anderson, G. (Com. v. Anderson, G.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Anderson, G., (Pa. Ct. App. 2025).

Opinion

J-A17040-23

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellee : : v. : : GEORGE ANDERSON : : Appellant : No. 1062 EDA 2022

Appeal from the Judgment of Sentence Entered February 28, 2022 In the Court of Common Pleas of Delaware County Criminal Division at No(s): CP-23-CR-0001662-2020

BEFORE: KING, J., SULLIVAN, J., and PELLEGRINI, J. *

MEMORANDUM BY KING, J.: FILED OCTOBER 10, 2025

Appellant, George Anderson, appeals from the judgment of sentence

entered in the Delaware County Court of Common Pleas, following his jury

trial conviction for firearms not to be carried without a license. 1 We affirm.2

The trial court set forth the relevant facts and procedural history of this

case as follows:

[The testimony adduced at the suppression hearing in this ____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 18 Pa.C.S.A. § 6106(a).

2 As we explain more fully infra, this Court originally affirmed Appellant’s judgment of sentence on December 5, 2023. See Commonwealth v. Anderson, No. 1062 EDA 2022 (Pa.Super. filed Dec. 5, 2023) (unpublished memorandum). Our Supreme Court subsequently granted allowance of appeal, and on July 23, 2025, the Court reversed and remanded the matter to this Court for further proceedings consistent with its opinion. See Commonwealth v. Anderson, ___ Pa. ___, 340 A.3d 297 (2025). J-A17040-23

matter is as follows.] On May 7, 2020, at approximately 10:54 p.m., Officer Jeffrey Walls of the Chester City Police Department was on routine patrol, in uniform and in a marked vehicle, in the area of the 200 Block of East 14th Street. Officer Walls was at a red light when he observed a silver Jeep traveling south in the 1400 block of Edgemont Avenue, with a green light, when the vehicle abruptly came to a stop upon observing the officer, and then made a left hand turn without a turn signal. Officer [Walls] observed the vehicle had a cracked windshield, and he could see that the inspection sticker was expired. Officer [Walls] then got behind the vehicle, and was unable to read the license plate due to a hazy plastic cover over top of it, and dim license plate lights, which is a violation of the Motor Vehicle Code.

Officer [Walls] performed a traffic stop, which was located in a high crime area, based on numerous shootings, robberies, drug sales, gang activity and homicides in the area. Upon pulling the vehicle over, [O]fficer [Walls] read the registration and determined it was expired. While Officer [Walls] was still seated in his patrol vehicle, he observed furtive movements towards the center console within the vehicle, and dropped his head down toward the center console.

Officer [Walls] approached the vehicle, and [Appellant] provided his information, which revealed his license was suspended (DUI related) and he was not the owner of the vehicle. Officer [Walls] smelled the odor of marijuana inside the vehicle and asked [Appellant] if he had anything illegal inside the vehicle, to which he responded, while opening the center console, I don’t have anything in here except hand sanitizer. Officer [Walls] found this strange and asked again if he had anything illegal, at which point [Appellant] became extremely nervous and [started] reaching around his person and [patting] his sides[.] Officer Walls asked [Appellant] to exit the vehicle and he performed a pat down search for weapons and was placed toward the rear of the vehicle.

Officer Litivenko arrived on location, and at that time, Officer Walls was performing a protective sweep of the areas of the vehicle within reach of [Appellant]. The rear of the center console was dislodged, and [O]fficer [Walls] could see the handle of a firearm. [Appellant] was placed into

-2- J-A17040-23

custody.

The vehicle was to be towed, in accordance with Department policy and procedures, which were followed, and an inventory search was performed. Officer Litivenko observed marijuana on the passenger side of the vehicle in plain sight upon opening the door.

[Appellant] was taken back to police headquarters where Officer Walls read him Miranda[3] and asked if he would be willing to give a written statement that it was his firearm. [Appellant] replied that he was the only person in the car, so it has to be his, but he would not give a written statement. There is nothing in the record that indicates the statement was the result of coercion or other unlawful means. [Appellant] knowingly and voluntarily made the statement to police.

(Trial Court Opinion, filed 11/8/22, at 2-3) (internal citations omitted).

Procedurally, the Commonwealth charged Appellant with possession of

a firearm prohibited, possession of a firearm with an altered manufacturer

number, firearms not to be carried without a license, possession of a controlled

substance, possession of marijuana, possession of drug paraphernalia, and

several violations of the motor vehicle code.

On January 12, 2021, Appellant filed a motion to suppress. The trial

court conducted a hearing on the motion on February 24, 2021, at which

Officer Walls testified to the above facts. The Commonwealth argued, inter

alia, that suppression should be denied because Appellant failed to carry his

burden to establish he had a reasonable expectation of privacy in the car

____________________________________________

3 Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966).

-3- J-A17040-23

where Appellant was not the registered owner of the vehicle. Appellant

presented no evidence at the suppression hearing, but he argued that the

Commonwealth’s evidence rebutted its own assertion that Appellant lacked a

reasonable expectation of privacy.

The trial court noted that it understood and agreed with the

Commonwealth’s argument, but the court ultimately took the matter under

advisement. On April 1, 2021, the court denied the motion to suppress, and

the case proceeded to trial. Following a bifurcated trial, a jury convicted

Appellant of carrying a firearm without a license, and acquitted Appellant of

possession of a firearm prohibited and possession of a firearm with an altered

manufacturer number.4 On February 28, 2022, the court sentenced Appellant

to 42 to 84 months’ incarceration. On March 30, 2022, Appellant filed a timely

notice of appeal.

As previously mentioned, on December 5, 2023, this Court affirmed the

judgment of sentence. In so doing, this Court held that Appellant had failed

to establish a reasonable expectation of privacy in the vehicle. 5 Appellant

petitioned the Pennsylvania Supreme Court for an allowance of appeal, which

4 The Commonwealth withdrew the other charges prior to trial.

5 Specifically, this Court explained that Appellant was not the registered owner

of the vehicle and he presented no evidence that he had permission to drive the car on the day of his arrest. Under such circumstances, this Court concluded that Appellant failed to demonstrate that he had the authority to operate the vehicle.

-4- J-A17040-23

the Court accepted to consider the following question:

Whether a defendant’s burden to establish a reasonable expectation of privacy at a suppression hearing requires that defendant to affirmatively present evidence of permission to use the vehicle where the defendant is not the registered owner of [the] vehicle but the Commonwealth’s evidence does not otherwise negate an expectation of privacy?

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Bluebook (online)
Com. v. Anderson, G., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-anderson-g-pasuperct-2025.