In the Int. of: T.T.-S., Appeal of: T.T.-S.

CourtSuperior Court of Pennsylvania
DecidedJune 26, 2026
Docket2455 EDA 2025
StatusPublished
AuthorMcLaughlin

This text of In the Int. of: T.T.-S., Appeal of: T.T.-S. (In the Int. of: T.T.-S., Appeal of: T.T.-S.) 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
In the Int. of: T.T.-S., Appeal of: T.T.-S., (Pa. Ct. App. 2026).

Opinions

J-A03018-26

2026 PA Super 136

IN THE INTEREST OF: T.T.-S., A : IN THE SUPERIOR COURT OF MINOR : PENNSYLVANIA : : APPEAL OF: T.T.-S., MINOR : : : : : No. 2455 EDA 2025

Appeal from the Dispositional Order Entered August 28, 2025 In the Court of Common Pleas of Philadelphia County Juvenile Division at No(s): CP-51-JV-0000156-2025

BEFORE: BOWES, J., McLAUGHLIN, J., and FORD ELLIOTT, P.J.E.*

OPINION BY McLAUGHLIN, J.: FILED JUNE 26, 2026

Appellant T.T.-S. appeals from the dispositional order adjudicating him

delinquent for violating 18 Pa.C.S.A. § 6110.1 (possession of a firearm by a

minor). Appellant argues that the juvenile court erred in denying his motion

to suppress evidence and admitting hearsay evidence. We find the

suppression issue meritorious. We therefore vacate the dispositional order,

reverse the order denying suppression, and remand for further proceedings.

The Commonwealth charged Appellant with possession of a firearm by

a minor and other charges. The charges arose after a juvenile probation officer

recovered a firearm during the search of a property. Previously, in a separate

case, Appellant had been found to have committed retail theft and was on

“interim” probation pending a dispositional hearing. The dispositional hearing

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-A03018-26

in that case had been deferred, and subsequently continued, at Appellant’s

request.

Before the adjudicatory hearing in this case, Appellant moved to

suppress the firearm. He argued that the warrantless search was without

consent, lacked probable cause, and went beyond the proper scope of a

probation search. See N.T., 7/23/25, at 9. He further argued that the

probation officer lacked authority under 42 Pa.C.S.A. § 6304(a)(1) to conduct

the search. He maintained that Section 6304(a)(1) permits probation officers

to conduct searches of children under their supervision as delinquent children,

and Appellant was not a delinquent child at the time of the search.

The juvenile court held a hearing on the motion on July 23, 2025. It

summarized the evidence at the suppression hearing as follows:

[Appellant] was on interim probation pursuant to a deferred adjudication for retail theft. The Juvenile Enforcement Team (JET) unit monitored his social media after the homicide of Noah Scurry, identifying [Appellant] as a member of the Whackers gang. (N.T. 7/23/25, at 14-15). On January 27, 2025, a music video was posted on YouTube showing [Appellant] posing with multiple firearms. (N.T. 7/23/25, at 14-17; C-1).

On January 28, 2025, Instagram posts depicted [Appellant] in a kitchen with two firearms on the counter. (N.T. 7/23/25, at 18-20; C-2, C-3). A Philadelphia Police Department firearms expert, Detective Speck, authenticated the firearms in the Instagram posts. (N.T. 7/23/25, at 19-20). [Appellant] reported to his assigned probation officer that he was living at 2510 North 31st Street. (N.T. 7/23/25, at 21). The JET unit verified this address and obtained supervisory approval from Nicole Hoffman for a property search based on reasonable

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suspicion of firearm possession in violation of probation conditions. (N.T. 7/23/25, at 22; C-4).

On February 19, 2025, a team consisting of JET probation officers, Philadelphia police officers, and sheriff[’]s deputies conducted the search. (N.T. 7/23/25, at 33). They knocked and announced their presence before entering. (N.T. 7/23/25, at 34-35). [Appellant] was found in the living room sitting on a couch and was detained for safety. When the couch was lifted, a firearm—a black Glock with a tan magazine and a machine gun conversion switch—was recovered underneath, loaded with 16 rounds plus one in the chamber. (N.T. 7/23/25, at 35-39, 48-49, 59-60; C-5, C-7, C-8). DNA analysis of the firearm's grip revealed a mixture from four individuals, with the likelihood that it included [Appellant’s] DNA and three unrelated individuals being 2.711 million times more likely to occur than originating from four random individuals of the Caucasian population, 343.9 thousand times more likely to occur than originating from four unknown or unrelated African American individuals, and 4.164 million times more likely to occur than originating from four random individuals of the Hispanic population. (N.T. 7/23/25, at 85-86; C-13). The firearm was confirmed operable by the Firearms Identification Unit. (C12). [Appellant’s] date of birth is [January 2008], making him a minor at the time. (C-14).

Trial Ct. Op., Oct. 22, 2025, at 3-4.

The court denied suppression. It immediately proceeded with the

adjudicatory hearing and found Appellant delinquent of possession of a firearm

by a minor. Following a later dispositional hearing, it placed Appellant on GPS

monitoring with house restrictions and other conditions. This timely appeal

followed.

Appellant raises the following issues:

A. Did the trial court err in denying Appellant’s motion to suppress, where the firearm was found as a result of an unwarranted search, and Appellant was not under probation supervision as a delinquent child or pursuant to a consent

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decree as required under 42 Pa.C.S. § 6304(a.1), but rather was on interim probation with his delinquency adjudication deferred?

B. Did the trial court err in denying Appellant’s motion to suppress, where the juvenile probation department acted as an agent of the police and allowed the police department to conduct a full law enforcement search without a warrant, in violation of Appellant’s rights as guaranteed for the Fourth and Fourteenth Amendments of the United States Constitution and Article I, Section 8 of the Pennsylvania Constitution?

C. Did the trial court err in denying Appellant’s motion to suppress, where the juvenile probation department lacked reasonable suspicion to execute the search at this address, because there was no nexus between the alleged violation and the property searched, in violation of Appellant’s rights as guaranteed by the Fourth and Fourteenth Amendments of the United States Constitution and Article I, Section 8 of the Pennsylvania Constitution?

D. Did the trial court err in improperly admitting hearsay evidence and relying upon it to find Appellant constructively possessed the firearm, and was that error not harmless, as it was the sole evidence introduced that Appellant committed the act of Violation of the Uniform Firearms Act, 18 Pa.C.S. § 6110.1?

Appellant’s Br. at 4-5 (answers of trial court omitted).

Appellant first challenges the denial of his motion to suppress. He argues

that the search was unlawful because he was not subject to warrantless

probationary searches under Section 6304(a.1)(1)(i). He maintains that that

provision only authorizes probation officers to search the person and property

of children “under their supervision as delinquent children or pursuant to a

consent decree[.]” 42 Pa.C.S.A. § 6304(a.1)(1)(i). He contends that he was

neither a delinquent child nor subject to a consent decree at the time of the

search.

-4- J-A03018-26

The Commonwealth responds that in its view, the juvenile court in the

underlying case had authority to supervise Appellant in the time between the

adjudicatory hearing and the dispositional hearing. For that reason, and

because Appellant had requested the deferment of the dispositional hearing,

the court properly imposed interim probation. The Commonwealth concludes

that “[i]t is absurd for [Appellant] to ask for a deferred adjudication and

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