Com. v. Davis, W.

CourtSuperior Court of Pennsylvania
DecidedDecember 22, 2025
Docket1119 WDA 2024
StatusUnpublished

This text of Com. v. Davis, W. (Com. v. Davis, W.) 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. Davis, W., (Pa. Ct. App. 2025).

Opinion

J-A09022-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : WILLIAM BENJAMIN DAVIS : No. 1119 WDA 2024

Appeal from the Suppression Order Entered August 20, 2024 In the Court of Common Pleas of Fayette County Criminal Division at No(s): CP-26-CR-0000565-2024

BEFORE: KUNSELMAN, J., NICHOLS, J., and LANE, J.

MEMORANDUM BY KUNSELMAN, J.: FILED: December 22, 2025

The Commonwealth appeals from the order granting William Benjamin

Davis’ motions to suppress the evidence gathered in connection with a traffic

stop and for a pretrial writ of habeas corpus. We agree with the

Commonwealth that the initial stop of Davis’ vehicle was valid. However, the

record supports Davis’ alternative argument that the police unreasonably

prolonged the stop. Furthermore, a pretrial writ of habeas corpus is not an

appropriate remedy for illegally obtained evidence. Therefore, we reverse the

suppression of evidence from the initial stop, affirm the suppression of

evidence obtained after the stop was unlawfully prolonged, and reverse the

grant of a pretrial writ of habeas corpus.

I. Factual and Procedural History

In the early hours of February 14, 2024, Pennsylvania State Police

Trooper James Tyler conducted a traffic stop of the vehicle Davis was driving. J-A09022-25

He arrested Davis and charged him with possession with intent to deliver,

driving an unregistered vehicle, obscured plate, and duty of operator.1

Davis exercised his right to a preliminary hearing on March 19, 2024.

At the preliminary hearing, Trooper Tyler testified that he was conducting

routine patrol when he saw Davis driving a silver Dodge Caravan. Trooper

Tyler explained that he started following the Caravan because Davis reacted

to seeing the police:

As I was sitting stationary, I observed [Davis], he passed by my stationary position. As I observed him, he was sitting behind the B pillar. Upon the observation of my marked vehicle, he re- positioned himself, sat up and then went ten and two on the steering wheel, the death grip, and proceeded to look at my marked patrol unit.

N.T., 3/19/24, at 5. Trooper Tyler testified that once he got behind Davis’

vehicle, he ran its Maryland registration number and saw that the registration

was suspended. Additionally, Trooper Tyler stated that the vehicle had a plate

cover that covered the word “Maryland” on the plate.

Trooper Tyler explained that after he saw the plate cover and received

a report that the registration was suspended, he activated his lights and sirens

to conduct a traffic stop. Once Davis stopped, Trooper Tyler and Trooper Luke

Martin spoke with Davis, who provided a valid Arizona driver’s license. The

officers asked Davis to show a valid insurance card; while they were waiting

for Davis to obtain the insurance card, they directed Davis to step outside of

____________________________________________

1 35 P.S. § 780-113(a)(30), 75 Pa.C.S. §§ 1301(a), 1332(b)(4), and 6308(a),

respectively.

-2- J-A09022-25

the vehicle. Eventually, Davis provided a screenshot of the insurance

information while he was standing at the front of the police vehicle.

At the preliminary hearing, Trooper Tyler stated that Davis’ answers to

the police questioning created suspicion. Davis was not able to provide his

intended destination to either officer, although he tried to show Trooper Martin

on his GPS unit and told Trooper Tyler he was staying with his cousin for one

to two days. Additionally, Trooper Tyler noted that he saw two cardboard

boxes in the vehicle but no luggage. Trooper Tyler stated that Davis was

“extremely nervous,” cracking his voice, fidgeting, and asking the reason for

all the questions. After Davis refused consent to search the vehicle,

approximately 17 minutes into the stop, Trooper Tyler contacted a K-9

Corporal, Christina Martz, for assistance for “a host of reasons.”

One of the reasons was [Davis’] short duration of time as far as the route he was taking, he wasn’t aware of . . . how long he was traveling in order to get to his destination. He wasn’t aware or wouldn’t even communicate his destination to me. When I asked him where he was going, he said it was, I am going . . . 58 minutes from where we are right now. He communicated that he was going to see his cousin who he hasn’t seen in a long time to which there was no luggage in the vehicle or anything resembling that he was visiting anywhere. Again with his nervous response to just my overall simple questions. And when I asked him . . . to exit the vehicle and when I was asking him about any contraband that might have been within the vehicle, just the nervous responses he had throughout the traffic stop.

Id. at 13–14.

Trooper Tyler testified that Davis waited on the police vehicle push bar

for “about an hour and a half” until Corporal Martz arrived. Corporal Martz

-3- J-A09022-25

deployed the State Police Drug Detection K-9, which alerted to the vehicle.

Police detained Davis and obtained a search warrant. The vehicle contained

almost five kilograms of cocaine.

Trooper Tyler indicated that there was a motor vehicle recording of the

entire traffic stop. At the time of the preliminary hearing, he stated that he

requested it but had not yet received a physical copy. Davis did not present

any testimony. After the preliminary hearing, all charges were held for court.

Davis filed an omnibus pretrial motion on May 16, 2024, including a

suppression motion and a habeas corpus petition. In his suppression motion,

Davis challenged both the initial stop and the continuation of the stop.

The case proceeded to a suppression hearing on June 12, 2024. Neither

party presented witness testimony. Instead, the Commonwealth indicated it

would introduce Davis’ preliminary hearing transcript and a video of the stop

“so that the court can view it as additional facts.” N.T., 6/12/24, at 3. The

Commonwealth did not have a copy of the video at the suppression hearing,

so the suppression court “figuratively” marked the video as Exhibit 1 and

received it into evidence.2 Id. Davis effectively agreed that the record, i.e.,

the transcript and the video, would be sufficient to resolve his motion:

THE COURT: And there was no need after you reviewed the [preliminary hearing] transcript for you to supplement [your omnibus] motion in any[ ]way?

2 Nearly five months later, the Clerk of Courts indicated that Exhibit 1 was turned over for filing purposes. Exhibit Receipt, 11/8/24.

-4- J-A09022-25

[Davis’ counsel]: You know, certainly there are possibly questions that I’ll have for the Trooper. But he’s not here. I think that everything was kind of answered here.

THE COURT: [It w]ould be contained in the viewing of it and in the transcript.

[Davis’ counsel]: Correct.

Id. at 4.

Based on this record, the parties then argued the issues Davis included

in his suppression motion: the legality of the traffic stop, and the legality of

Davis’ prolonged detention. Cf. Omnibus Pre-Trial Motion, 5/16/24, at ¶ 26,

a–g. Davis, relying on his notes of the video, argued that the police stopped

him without justification and illegally prolonged the stop. N.T., 6/12/24, at

5–13. The Commonwealth first argued that the police had authority to

conduct the stop to address the partially obstructed license plate and to

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