Com. v. Pearson, J.

CourtSuperior Court of Pennsylvania
DecidedJanuary 17, 2025
Docket418 WDA 2023
StatusUnpublished

This text of Com. v. Pearson, J. (Com. v. Pearson, J.) 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. Pearson, J., (Pa. Ct. App. 2025).

Opinion

J-A26029-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JARMAR PEARSON : : Appellant : No. 418 WDA 2023

Appeal from the Judgment of Sentence Entered March 16, 2023 In the Court of Common Pleas of Allegheny County Criminal Division at No(s): CP-02-CR-0001155-2022

BEFORE: BOWES, J., BECK, J., and BENDER, P.J.E.

MEMORANDUM BY BECK, J.: FILED: January 17, 2025

Jarmar Pearson (“Pearson”) appeals from the judgment of sentence

imposed by the Allegheny County Court of Common Pleas (“trial court”)

following his convictions for two counts of driving under the influence (“DUI”)

and associated summary traffic offenses. Pearson asserts that the sheriff who

effectuated the traffic stop was unauthorized to do so, thus requiring

suppression of all evidence. We affirm.

On January 3, 2022, Deputy Zachary Weaver of the Allegheny County

Sheriff’s Office observed a vehicle swerve into the opposing lane of traffic,

almost striking an oncoming vehicle. Deputy Weaver checked the vehicle’s

registration and learned that it had expired. Based on the traffic violations,

he stopped the vehicle and spoke to Pearson, the sole occupant. Deputy

Weaver believed that Pearson was intoxicated and asked him to submit to field

sobriety tests. Pearson agreed, and based on his performance was arrested. J-A26029-24

He consented to a blood draw; testing established that his blood contained

Fentanyl and its metabolites. The Commonwealth thereafter charged Pearson

with two DUI violations and two summary traffic violations.

Pearson sought to suppress all evidence on the basis that sheriffs lack

both statutory and common law authority to enforce the Vehicle Code

violations cited by Deputy Weaver as the basis for the stop. The trial court

denied the suppression motion. Subsequently, following a bench trial, Pearson

was found guilty and sentenced to three to six days of incarceration and a six-

month period of probation. He timely filed a notice of appeal, raising the same

suppression issue in his concise statement.

The trial court filed its Rule 1925 opinion, concluding that Deputy

Weaver was authorized to seize the vehicle under two sources of power. First,

the trial court noted that “Allegheny County is a second-class county,” and

sheriffs therein are statutorily defined as police officers authorized to enforce

the Vehicle Code. Trial Court Opinion, 1/30/2024, at 4 (pagination supplied).

Alternatively, the trial court determined that Deputy Weaver validly seized

Pearson’s vehicle under a common law power to address breaches of the

peace. Id. at 5. On appeal, Pearson contends that the trial court erred and

that it should have granted his motion to suppress. Pearson’s Brief at 7.

“The suppression court’s findings of fact bind an appellate court if the

record supports those findings. The suppression court’s conclusions of law,

however, are not binding on an appellate court, whose duty is to determine if

the suppression court properly applied the law to the facts.” Commonwealth

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v. Coles, 317 A.3d 659, 663 (Pa. Super. 2024) (citations and quotation marks

omitted). We apply a de novo standard to questions of law. Id.

Preliminarily, we agree that Pearson would be entitled to suppression of

all evidence as a matter of law if Deputy Weaver lacked authority to seize the

vehicle. That the traffic stop would be constitutionally permissible if observed

by a police officer authorized to enforce the Vehicle Code is irrelevant. See

Commonwealth v. Price, 672 A.2d 280, 284 (Pa. 1996) (concluding that FBI

agent Mark Sites was not authorized to make a traffic stop that led to DUI

charges, and finding that “[t]he fact that [Price] could have lawfully been

arrested by someone other than Agent Sites is clearly inconsequential to a

determination of whether Agent Sites’ actions warrant the remedy of

exclusion”).

Our task, therefore, is to determine whether Deputy Weaver was

authorized by the General Assembly to enforce the Vehicle Code, which

permits “police officers” to seize a vehicle if he or she reasonably suspects a

vehicular violation. 75 Pa.C.S. § 6308(b). “Police officer” is defined as “[a]

natural person authorized by law to make arrests for violations of law.” Id. §

102. The legislative branch has elsewhere defined “police officer” in two

contexts that are pertinent to our analysis. Section 103 of the Crimes Code

defines the term “police officer,” in relevant part, to “include the sheriff of a

county of the second class and deputy sheriffs of a county of the second class

who have successfully completed the requirements under ... the Municipal

-3- J-A26029-24

Police Education and Training Law [MPETL].” 18 Pa.C.S. § 103.1 The MPETL2

sets forth standards all municipalities must follow for training police officers,

and it again defines a “police officer” as, inter alia, “[a] deputy sheriff of a

county of the second class.” 53 Pa.C.S. § 2162(2). A county of the second

class is defined as those “having a population of at least 1,000,000 but less

than 1,500,000 inhabitants.” 16 Pa.C.S. § 310(2). Allegheny County meets

that criterion.3

In support of his claim of error, Pearson relies on Commonwealth v.

Marconi, 64 A.3d 1036, (Pa. 2013), a case involving sheriffs from Warren

and Forest Counties establishing temporary sobriety checkpoints. The

Marconi Court acknowledged that section 102 of the Vehicle Code “facially ...

applies broadly to anyone with a power of arrest.” Id. at 1041. The Court

declined to read that language literally, as citizens also retain a common-law

____________________________________________

1 Deputy Weaver testified that to become a sheriff he was required to complete

a six-and-a-half month training at the Allegheny County Police Training Academy. N.T., 1/19/2023, at 4.

2 53 Pa.C.S. §§ 2161–2172.

3 The “classification of counties shall be ascertained and fixed according to population by reference to the Federal decennial census.” 16 Pa.C.S. § 311(a). There is a certification process for reclassifications, as “it is the intent of this section that the classification of a county may not be changed because its population has decreased at the time … but rather only after the change is demonstrated by two Federal decennial censuses ….” Id. § 311(c). The 2020 census lists Allegheny County as having a total population of 1,250,578. https://data.census.gov/profile/Allegheny_County,_Pennsylvania?g=050XX0 0US42003 (last visited Jan. 7, 2025).

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arrest power and courts “presume that the General Assembly did not intend

unreasonable results.” Id. Our Supreme Court concluded that the definition

“refers to some form of legal authorization beyond a mere common-law power

shared among Pennsylvania citizens.” Id. “Since such shared power

represents the extent of sheriffs’ arrest authority as determined by prevailing

precedent (and in the absence of specific expansion by the Legislature), we

conclude that sheriffs and their deputies are not ‘police officers’ under the

Vehicle Code.” Id.

In reliance on Marconi, Pearson contends that “[t]he Court ... held that

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Related

Commonwealth v. Price
672 A.2d 280 (Supreme Court of Pennsylvania, 1996)
Commonwealth v. Marconi
64 A.3d 1036 (Supreme Court of Pennsylvania, 2013)

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