Com. v. Livingston, C.

CourtSuperior Court of Pennsylvania
DecidedJanuary 14, 2026
Docket2540 EDA 2022
StatusUnpublished
AuthorOlson

This text of Com. v. Livingston, C. (Com. v. Livingston, C.) 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. Livingston, C., (Pa. Ct. App. 2026).

Opinion

J-A28002-23

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : CORDELL ANTHONY LIVINGSTON : No. 2540 EDA 2022

Appeal from the Order Entered August 31, 2022 In the Court of Common Pleas of Delaware County Criminal Division at No(s): CP-23-CR-0001995-2021

BEFORE: OLSON, J., STABILE, J., and COLINS, J.*

MEMORANDUM BY OLSON, J.: FILED JANUARY 14, 2026

The Commonwealth of Pennsylvania appeals from the order entered on

August 31, 2022, which granted the suppression motion filed by the

defendant, Cordell Anthony Livingston (“the Defendant”). We affirm.

On May 13, 2020, the Defendant was arrested and charged with a

number of crimes, including possessing a controlled substance with the intent

to deliver (“PWID”) and criminal conspiracy. 1 The Defendant filed a pre-trial

motion, where he sought to suppress certain evidence against him. See The

Defendant’s Pre-Trial Motion, 7/8/21, at 1-3.

On July 22, 2022, the trial court held a suppression hearing. The trial

court ably summarized the evidence it heard during the hearing: ____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 35 P.S. § 780-113(a)(30) and 18 Pa.C.S.A. § 903, respectively. J-A28002-23

On May 13, 2020 at approximately 8:30 a.m. Trooper James Nolan of the Pennsylvania State Police was in his fully marked patrol vehicle observing southbound traffic on Interstate 95 in Tinicum Township, Pennsylvania. At the time and place in question, the trooper observed a black Infinity G35 with heavily tinted windows bearing a Virginia license plate and began to follow same. The trooper clocked the vehicle in question at 70 m.p.h. for [0.3] miles with his calibrated police vehicle which was also equipped with a motor vehicle recorder [(“MVR”)]. The speed limit in this area on Interstate 95 is 55 [miles per hour.]

The trooper testified that although through training and experience it was his belief that a lot of people from out of state come to Philadelphia to obtain large quantities of drugs and take them back to their respective cities he did not know whether this vehicle had actually stopped in Philadelphia or not. After the vehicle in question was stopped Trooper Nolan exited his patrol car and approached [the Defendant’s] vehicle from the passenger side during which time he observed “[a] lot of movement within the vehicle. It looked like people were moving around of [sic] the vehicle and the car was bouncing back and forth as if they switched seats.” The [trooper] testified that such movement was unusual in his experience.

During the suppression hearing, the tape of the [MVR] in Trooper Nolan's vehicle was placed into evidence without objection. All counsel agreed that the court could review the MVR in its entirety at a later date in chambers. The court did, in fact, conduct such review in chambers.

The review revealed that as the Trooper approached [the Defendant’s] vehicle after it [had] been pulled over there was some perceptible movement [in] the vehicle consistent with a person or persons moving around within the interior of said vehicle.

When asked about the movement inside the car, [the Defendant, who was then in the passenger’s seat,] told Trooper Nolan that [he and his co-defendant, Jonathan Moore (“Mr. Moore”)] had switched seats. Upon his initial approach the passenger window was cracked about [four] inches and

-2- J-A28002-23

the trooper immediately smelled a very large odor of marijuana and air fresheners such as cologne along with little trees hanging on the floorboard which Trooper Nolan felt was indicative of a criminal element within the vehicle.

[The Defendant and Mr. Moore] produced their driver's licenses upon request. [The Defendant’s] license was suspended[;] however, Mr. Moore’s license was valid. The vehicle's registration came back to Sharon Horton. Neither occupant provided any information about Ms. Horton and the vehicle had not been reported stolen. The trooper [did not] recall ever asking the occupants what their relationship may have been to the owner [of the vehicle]. When asked why that issue was not raised, the trooper stated that he made the decision to conduct a probable cause search of the vehicle as soon as he smelled the marijuana.

Although Trooper Nolan told the court he smelled the odor of burnt marijuana he had earlier told defense counsel that he could not recall if the smell was from fresh marijuana or not. Trooper Nolan was told that the occupants had changed seats in the vehicle, although there is no indication in the record that the trooper interrogated the passengers as to the reason for the switch or that either occupant volunteered such information.

Neither of the occupants of the vehicle consented to a search of the car and Trooper Nolan conceded that there was nothing precluding him or his fellow officer from obtaining a search warrant for the vehicle in question.

...

When asked by the [trial court] why the ownership issue was not pursued, Trooper Nolan [testified]:

I think at that point, again, pre-Alexander,[2] I knew that I was going to search the vehicle anyway ... I kind of was just trying to get straight to the point. ____________________________________________

2 The Pennsylvania Supreme Court decided Commonwealth v. Alexander in December 2020. In Alexander, the Supreme Court overruled prior (Footnote Continued Next Page)

-3- J-A28002-23

[As Trooper Nolan testified: “in the rear seat of the vehicle, I noticed the armrest was down, which then has a little lever door that you can gain entry to the trunk. I opened that [little lever] door, and there were two pounds of marijuana vacuum-sealed sitting right there.”]

Trial Court Opinion, 1/5/23, at 3-5 (citations omitted).

On August 31, 2022, the trial court granted the Defendant’s motion and

suppressed all evidence against the Defendant. See Trial Court Order,

8/31/22, at 1-6. Regarding the Commonwealth’s claim that the Defendant

failed to demonstrate an expectation of privacy in the vehicle, the trial court

declared: “[i]n the instant matter the Commonwealth failed to establish [the

Defendant’s] lack of privacy interest. Accordingly, the burden never shifted

to the [Defendant] and the Commonwealth’s argument must fail.” Trial Court

Statement of Facts, 8/31/22, at 5.

The Commonwealth filed a timely notice of appeal and, within its notice,

the Commonwealth properly certified that the trial court’s order “will terminate

or substantially handicap the prosecution.” Commonwealth’s Notice of Appeal,

9/29/22, at 1; see also Pa.R.Crim.P. 311(d). The Commonwealth raises one

claim to this Court:

Did the lower court err in granting [the Defendant’s] motion to suppress where: (1) the evidence that [the Defendant] ____________________________________________

precedent and held that, under Article I, Section 8 of the Pennsylvania Constitution, “warrantless vehicle searches require both probable cause and exigent circumstances; one without the other is insufficient.” Commonwealth v. Alexander, 243 A.3d 177, 207 (Pa. 2020) (quotation marks and citations omitted).

-4- J-A28002-23

had been driving an out-of-state car registered to someone else was sufficient to meet the Commonwealth’s initial burden of production; and (2) [the Defendant] did not even attempt to establish a reasonable expectation of privacy in the car?

Commonwealth’s Brief at 4.3

On appeal to this Court, we originally vacated the trial court’s

suppression order and remanded for further proceedings. We originally

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Bluebook (online)
Com. v. Livingston, C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-livingston-c-pasuperct-2026.