Commonwealth v. Snyder

60 A.3d 165, 2013 Pa. Super. 10, 2013 WL 204761, 2013 Pa. Super. LEXIS 15
CourtSuperior Court of Pennsylvania
DecidedJanuary 18, 2013
StatusPublished
Cited by26 cases

This text of 60 A.3d 165 (Commonwealth v. Snyder) 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
Commonwealth v. Snyder, 60 A.3d 165, 2013 Pa. Super. 10, 2013 WL 204761, 2013 Pa. Super. LEXIS 15 (Pa. Ct. App. 2013).

Opinions

OPINION BY

ALLEN, J:

William Harry Snyder, (“Appellant”), appeals from the judgment of sentence entered following his conviction on one count of obstructing the administration of law enforcement or other governmental official after Appellant divulged the plans of the Aliquippa Police Department to acquire search warrants for residences in the Valley Terrace apartment complex.1 We affirm the judgment of sentence.

The pertinent facts and procedural history may be summarized as follows: Shortly after midnight on December 28, 2010, Detective Donald Anthony Couch of the City of Aliquippa Police Department received a report that a fatal shooting had occurred in Aliquippa, Pennsylvania, and that the victim, Robert Hall, was discovered in a parking lot at the Valley Terrace apartment complex. N.T., 9/15/11, at 5-6. Valley Terrace employed Victory Security Company to provide armed security guards at the apartment complex, and shortly after the shooting, Detective Couch learned that three Valley Terrace Security Officers had witnessed part of the activity leading up to the shooting. Id. at 7-8. Detective Couch commenced an investigation of the homicide and on December 29, 2010, convened a meeting to discuss the status of the investigation. Because of a history of good rapport between the City of Aliquippa Police and the Victory Security guards at Valley Terrace, Detective Couch invited three security guards from Victory Security, including Appellant, to participate in the December 29, 2010 meeting as “witnesses” and to “shed light” on the investigation. Id. at 9-14. Also present at the meeting were several other Ali-quippa Police officers, and several Beaver County Detectives. Id. Detective Couch [168]*168informed the Victory Security guards that all discussions taking place at the meeting were highly confidential. Id. at 13. Among the matters discussed at this meeting was Detective Couch’s intent to obtain search warrants for several Valley Terrace apartments, including a search warrant for the apartment of an individual named Roger Henderson. Id. at 12.

At the time of the December 29, 2010 meeting with Detective Couch, Appellant had been employed as a security guard at Valley Terrace for approximately three months. N.T., 9/14/11 at 61. On January 1, 2011, three days after the meeting with Detective Couch, Appellant became involved in a verbal altercation with Thomas Allman and James English, his supervisors at Victory Security. N.T., 9/14/11, at 54-56; 71-74. As a consequence, Appellant was discharged from his job duties as a security guard at Valley Terrace. Id. at 63. That evening, Appellant visited the apartment of Roger Henderson, a Valley Terrace resident, and informed Mr. Henderson that the Aliquippa Police would be acquiring search warrants for Mr. Henderson’s apartment as well as several other residences in the Valley Terrace apartment complex. Id. at 81-82. Mr. Henderson informed his mother, with whom he shared the residence, and several other individuals, about the impending search warrants. Id. at 82.

The following day, Mr. Henderson spoke with Mr. Allman and Mr. English, Appellant’s supervisors with Victory Security, about his conversation with Appellant. Id. at 56. Following the conversation with Mr. Henderson, Mr. English and Mr. All-man informed the Aliquippa Police Department that the search warrants had been compromised. Id. at 58. Detective Couch instructed Mr. Allman to complete a detailed report and submit it to the Aliquippa police, and Mr. Allman complied. N.T., 9/15/11, at 16. Detective Couch then interviewed Mr. Allman, Mr. English and Mr. Henderson, after which the Detective consulted with the District Attorney’s office, who recommended that Appellant be charged with violating 18 Pa.C.S.A. § 5101. Id.

On January 3, 2011, Detective Couch contacted Appellant and asked him to come to the Aliquippa Police Station. On January 4, 2011, at 9:30 a.m., Appellant arrived at the police station. At the station, Detective Couch led Appellant to a conference table. Without issuing Miranda2 warnings, Detective Couch began to explain to Appellant that he was aware that Appellant had divulged the plans to execute search warrants, that he had spoken with and interviewed the people involved, and that he had a warrant for Appellant’s arrest. Appellant then informed Detective Couch that he had told Mr. Henderson about the search warrants because he was mad at his supervisors. N.T., 9/14/11, at 15; N.T., 9/15/11, at 17-20. Detective Couch then provided Appellant with Miranda warnings, after which Appellant indicated that he would not make any more statements, and declined to sign a Miranda waiver. Appellant was arrested and transported to a Magisterial District Judge for arraignment. N.T., 9/15/11, at 22.

Thereafter, Detective Couch decided that it would not be practical to execute the search warrants because of Appellant’s having tipped off Mr. Henderson, which greatly decreased the likelihood of finding evidence. Id. at 25-26. Moreover, Detective Couch was concerned that the search warrants would be dangerous to execute without the element of surprise. Detective Couch therefore opted not to execute the [169]*169search warrants and testified that Appellant’s actions significantly compromised his investigation into the death of Robert Hall.3 See also Trial Court Opinion, 3/8/12, at 1-8.

On February 7, 2011, Appellant was charged with one count of Obstructing the Administration of Law Enforcement of Other Governmental Official, 18 Pa.C.S.A. § 5101. On September 14, 2011, prior to the commencement of jury trial, Appellant made an oral motion to suppress the incriminating statements he had made to Detective Couch on January 3, 2011. Following a hearing, the trial court denied Appellant’s motion. Jury trial commenced that same day. At trial, the Commonwealth presented the testimony of Detective Couch, Thomas Allman, James English, and Roger Henderson. Appellant opted not to testify at trial. On September 15, 2011, the jury found Appellant guilty, and on November 9, 2011, the trial court sentenced Appellant to serve one year of probation. No post-sentence motions were filed. Appellant filed a timely notice of appeal on December 7, 2011. Both Appellant and the trial court have complied with Pa.R.A.P. 1925.

Appellant raises the following issues for our review:

I. WHETHER THE TRIAL COURT ERRED IN NOT SUPPRESSING THE APPELLANT’S INCRIMINATING STATEMENT MADE TO DETECTIVE SERGEANT COUCH WHILE IN THE SETTING OF CUSTODIAL INTERROGATION PRIOR TO BEING GIVEN MIRANDA WARNINGS?
II. WHETHER THE COMMONWEALTH PRESENTED SUFFICIENT EVIDENCE TO CONVICT APPELLANT OF OBSTRUCTING ADMINISTRATION OF LAW OR OTHER GOVERNMENTAL FUNCTION BY INTENTIONALLY OBSTRUCTING, IMPAIRING OR PERVERTING THE ADMINISTRATION OF LAW BY UNLAWFUL PHYSICAL INTERFERENCE OR OBSTACLE OR BY BREACH OF AN OFFICIAL DUTY?

Appellant’s Brief at 6.

In his first issue, Appellant argues that the trial court erred in failing to suppress the incriminating statements he made to Detective Couch. Appellant’s Brief at 14-17. Our appellate standard of review of suppression motions is as follows:

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Cite This Page — Counsel Stack

Bluebook (online)
60 A.3d 165, 2013 Pa. Super. 10, 2013 WL 204761, 2013 Pa. Super. LEXIS 15, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-snyder-pasuperct-2013.