Com. v. Lethridge, T.

CourtSuperior Court of Pennsylvania
DecidedSeptember 12, 2025
Docket789 WDA 2024
StatusUnpublished

This text of Com. v. Lethridge, T. (Com. v. Lethridge, T.) 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. Lethridge, T., (Pa. Ct. App. 2025).

Opinion

J-S24042-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : TYLER LETHRIDGE : : Appellant : No. 789 WDA 2024

Appeal from the Judgment of Sentence Entered January 29, 2024 In the Court of Common Pleas of Allegheny County Criminal Division at No(s): CP-02-CR-0003461-2023

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

MEMORANDUM BY LANE, J.: FILED: September 12, 2025

Tyler Lethridge (“Lethridge”) appeals from the judgment of sentence

imposed following his convictions for one count of possession of a controlled

substance and two counts of possession with intent to deliver (“PWID”).1 We

affirm.

In 2023, Pittsburgh Police Officer Alexander Franks (“Officer Franks”)

and his sergeant were conducting surveillance from the sixth floor of a building

in an area of Pittsburgh where police had “received numerous . . . complaints

about narcotics use [and] sales[, and where there had been] several

overdoses.” N.T., 1/29/24, at 7. At the time of this surveillance, Officer

Franks had received training on “how to observe different styles of narcotics

transactions, how to apprehend individuals [engaging in narcotics

transactions, and] how to [recognize] undercover buys[.]” Id. at 6. At around ____________________________________________

1 See 35 P.S. § 780-113(a)(16), (30). J-S24042-25

2 to 3 p.m., the officers turned their attention to a man, later identified as

Lethridge, standing across the street. Lethridge “appeared to be the only

person in that immediate area that was not a drug user[,]” as he had not been

observed using any drugs or exhibiting any of the typical signs of drug use,

such as “nodding off[,]” but was instead just standing on the steps of a church

“in plain clothes, hand in pocket, looking around a lot.” Id. at 7.

With the assistance of binoculars, Officer Franks witnessed Lethridge

separately interact with two individuals. When Lethridge “was [first]

approached by an unknown black male[, Lethridge bladed his body,] pulled

out a small plastic baggie[,] and handed [the man] . . . a small white rock[,]”

which Officer Franks believed to be crack cocaine, in exchange for U.S.

currency. Id. at 8, 19. Accordingly, Officer Franks believed he had just

observed a narcotics transaction. A “minute or two later[, Lethridge] was

approached by a white female who did the same thing essentially[,]” as

Lethridge “pulled out a small plastic baggie and handed her a small white rock”

in exchange for U.S. currency. Id. at 8. Officer Franks again believed this

exchange constituted a narcotics transaction.

Following this second exchange, Officer Franks instructed another officer

in the area to take Lethridge into custody. The officers did not apprehend the

two individuals who they believed to have purchased cocaine from Lethridge.

While Lethridge was in custody, Officer Franks searched his person and

recovered a “digital scale[,]” approximately $600 in U.S. currency, and “a

small plastic baggie of what [the officer] believed at the time to be crack

-2- J-S24042-25

cocaine.” Id. at 10. The Commonwealth subsequently charged Lethridge with

the above-listed crimes.

Prior to trial, Lethridge filed a motion to suppress, arguing that the

discovery of the crack cocaine, U.S. currency, and digital scale should be

suppressed, as police arrested and illegally searched his person without

probable cause and in violation of his rights pursuant to the Pennsylvania and

United States Constitutions. See Motion to Suppress, 9/21/23, at 2-3. The

trial court held a hearing on the motion, during which the Commonwealth

presented testimony from Officer Franks, who testified to the above sequence

of events. At the conclusion of the hearing, the trial court denied suppression,

finding that police had requisite probable cause to arrest and search Lethridge.

The matter proceeded directly to a non-jury trial that same day.

Notably, because Officer Franks had just testified at the preceding suppression

hearing, the parties agreed to incorporate the transcript of his testimony into

evidence at trial. See N.T., 1/29/24, at 28-29. As such, when the

Commonwealth presented testimony from Officer Franks once more, his

testimony was brief and only further elucidated that: (1) he believed that the

plastic baggie recovered from Lethridge contained crack cocaine intended for

distribution, as people who sell narcotics in the officer’s experience often

either carry individual “small[,] knotted baggies or one . . . larger baggie with

multiple small rocks inside[,]” as was the case here; and (2) the recovered

0.824 grams of the substance in the plastic bag was sent to the crime lab,

where it tested positive for cocaine. Id. at 30-32.

-3- J-S24042-25

Lethridge additionally testified in his defense. Relevantly, Lethridge

testified that on the afternoon of his arrest, he had just gotten off a bus “from

Wilkinsburg[,]” where he “had smoked some crack [and] snorted some

fentanyl.” Id. at 37. Lethridge clarified that he “usually snorts [his] coke and

[his] fentanyl . . . off a scale.” Id. at 38-39. Upon exiting the bus, Lethridge

stated that he immediately traveled to the church, which acted as a homeless

shelter overnight, as he “usually tr[ied] to get there early so [he could] get a

nice spot in the shelter[,]” ahead of the “hundreds of people” who also

typically use it. Id. at 37. Lethridge maintained that while he was waiting on

the steps to the church, someone “immediately” approached him with an offer

to sell him two packs of cigarettes, and that he subsequently purchased them

for a total of ten dollars. Id. Lethridge next explained that after purchasing

the cigarettes, “a lady asked . . . to buy one from” him. Id. Lethridge

elaborated, however, that after the lady “gave [him] a dollar, and before [he]

even got to . . . open up . . . one of the packs of cigarettes,” police had arrested

him. Id. Lethridge asserted that “at no point” prior to this did he “hand over

a small plastic baggie to anyone[,]” as the drugs therein were only for his

“personal use.” Id. at 40.

At the conclusion of trial, the court convicted Lethridge of one count of

possession of a controlled substance and two counts of PWID. The matter

proceeded directly to sentencing, whereupon the court imposed an aggregate

sentence of twelve to twenty-four months’ imprisonment, followed by two

years’ probation. Lethridge thereafter filed two post-sentence motions, which

-4- J-S24042-25

the trial court denied.2 Lethridge subsequently filed a timely notice of appeal,

and both he and the trial court complied with Pa.R.A.P. 1925.3

Lethridge raises the following issues for our review:

1. Whether the trial court erred when it denied . . . Lethridge’s motion to suppress all evidence derived from the unlawful search incident to arrest as fruit of the poisonous tree because Officer Franks did not have probable cause to conduct a warrantless arrest?

2. Whether the evidence was insufficient to convict . . . Lethridge of delivery of a controlled substance where the Commonwealth failed to prove, beyond a reasonable doubt, that . . . Lethridge delivered a controlled substance to either of the unknown individuals?

3. Whether the evidence was insufficient to convict . . .

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Com. v. Lethridge, T., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-lethridge-t-pasuperct-2025.