Commonwealth v. Mayhugh

75 Pa. D. & C.2d 552, 1976 Pa. Dist. & Cnty. Dec. LEXIS 241
CourtPennsylvania Court of Common Pleas, Somerset County
DecidedSeptember 20, 1976
Docketno. 106 Criminal 1975
StatusPublished
Cited by1 cases

This text of 75 Pa. D. & C.2d 552 (Commonwealth v. Mayhugh) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Somerset County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Mayhugh, 75 Pa. D. & C.2d 552, 1976 Pa. Dist. & Cnty. Dec. LEXIS 241 (Pa. Super. Ct. 1976).

Opinion

SHAULIS,/.,

This matter is before the court on defendants’ motions in arrest of judgment and for a new trial. Applications to suppress evidence were filed and heard by the court andón January 12,1976, and on February 25,1976, orders refusing the applications to suppress were entered. Thereafter, the matter came on for trial before this court without a jury and defendants were both convicted of possession of a controlled substance, a misdemeanor. The motions in arrest of judgment and for a new trial are primarily based on the court’s refusal to suppress the evidence and the admission into evidence of a quantity of marijuana and smoking paraphernalia allegedly found in the automobile of defendant, Gary Wedge.

[554]*554The incident in question occurred at approximately 12:30 a.m. on March 23, 1975, on lands which were leased to the Game Commission. A game protector, while on patrol, came upon a motor vehicle which was parked on the leased land without its lights on. The game protector testified that he stopped and approached the automobile on foot at which time he smelled the odor of what he believed to be marijuana. When he arrived at the vehicle, he ordered the occupants out, and, according to his testimony, as the occupants were exiting the vehicle he noticed a bag of what he believed to be marijuana on the floor “in plain view.” He then turned to the occupants and stated: “Do you know what this means—I’m placing you under arrest.” When one of the occupants, Mayhugh, asked to relieve himself, the game protector seized another bag of what he believed to be marijuana when he observed Mayhugh discard some object as he was relieving himself. The occupants were then taken to the police barracks in Meyersdale at which time a further search was conducted by the State Police.

The first question to be answered relative to the suppression of the evidence concerns the authority of a game protector to make warrantless arrests and conduct searches. The powers of a game protector are specifically provided for by statute. The Act of June 3,1937, P.L. 1225,34P.S. §1311.214®, provides that a game protector has the power, “[t]o arrest without warrant any person found in the act of violating any of the provisions of this act, or in pursuit immediately following such violation.” Nowhere is it statutorily provided that game protectors shall have the same power to make warrant-less arrests as police officers. Their power to make warrantless arrests is strictly limited by statute to [555]*555those situations in which a game protector apprehends a person who is in the act of committing a game violation, or who is in flight immediately following such a violation. If no such situation exists, then the legality of the warrantless arrest must be judged relative to the power of a private citizen to make a warrantless arrest.

It should be noted that section 1311.214 gives very broad powers to game protectors to conduct searches and seizures. In fact, the statute on its face gives broader powers to game officers than the powers granted to police officers to conduct searches and seizures. It is realistic, therefore, to presume that this area of The Game Law must be qualified so as to be consistent with the constitutional restrictions against unreasonable searches and seizures. (Compare, for example, the limitations imposed in section 1221(b) of The Vehicle Code of April 29, 1959, P.L. 58, as amended.) Therefore, before a game protector can stop a vehicle or conduct a search, there must be present some reasonable grounds (suspicion) based on articulable facts which would lead a game protector to believe that game violations may be occuring or have occurred. Even then, the game statute provides, section 1311.214(h), that before an inspection or search can be conducted, the game protector “shall be in uniform and display his badge or other insignia of identification and shall state to the person in charge of said vehicle . . . the purpose of the inspection or search. . . .” These requirements have apparently been strictly enforced. See Commonwealth v. Savage, 17 D. & C. 2d 697 (1959).

Under the facts as testified to by the game protector, it would be valid to hold that he had, upon seeing a motor vehicle parked late at night, or early [556]*556morning, on land leased to the Game Commission, reasonable grounds to conduct a further investigation in his capacity as a game protector. As he approached the car, however, he sensed the odor of what he believed to be marijuana. At this point, two conclusions can be drawn. One is that he realized that the occupants were simply a group of young people who had come upon the game lands only for the purpose of finding a secluded spot to smoke marijuana. In such case, the game protector should have realized that there was no game law violation being committed, and, therefore, all of his subsequent acts should be judged on the basis of the conduct of a private citizen. The second conclusion is that even though he smelled the odor of marijuana and could presume that the occupants of the vehicle were there for the purpose of smoking the stuff, he could not be entirely sure that game violations had not occurred unless he conducted a further inquiry. In this instance, the game protector’s authority would be determined relative to his power as a game protector. In reality, it would be more likely to presume that upon his first smelling marijuana, he knew that no game violations were being committed but it would be reasonable to find that a further investigation would still be mandated within his capacity as a game protector.

If it is assumed that the game protector was still acting within his authority at the time he ordered the occupants to get out of the car and thereupon observed and seized the first bag of marijuana on the floor of the vehicle, it is difficult to see how the seizure could be justified under section 1311.214(h) of The Game Law. This section states that if any inspections or searches are conducted, the game protector must identify himself as a game [557]*557protector and inform the person who was in charge of the vehicle that the purpose of the search was to discover items which would evidence a game law violation. This, the game protector did not do and any subsequent seizure of the person or property, or search of the vehicle would be unjustified under the game law provisions. Furthermore, his power to arrest without a warrant, under The Game Act is limited to those situations in which a game violation has occurred.

The testimony of the game protector confirms the conclusion that upon his smelling of the marijuana, he proceeded on the basis of pursuing this potential crime as opposed to any game violation. At this point, we are dealing with the game protector’s right to make a warrantless arrest as a private citizen. Certainly, a private citizen would have no authority to order people out of a car and make a search of the vehicle unless it was pursuant to a lawful arrest. It really can’t even be said that any evidence seized by the game protector would have been the equivalent of having it seized by a private citizen because he was at all times acting, at least in his eyes and the eyes of the occupants, under the color of some police or government authority. The critical question then seems to be whether, at the time he smelled the marijuana, he had the authority as a private citizen to make a lawful warrantless arrest which would justify the search incident thereto.

The following comment concerning a private person’s authority to arrest is provided in 3 P.L.E. 38, §5: [558]

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Cite This Page — Counsel Stack

Bluebook (online)
75 Pa. D. & C.2d 552, 1976 Pa. Dist. & Cnty. Dec. LEXIS 241, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-mayhugh-pactcomplsomers-1976.