Commonwealth v. Bucalo
Annotate this CaseDefendant moved to suppress evidence obtained from a search of her vehicle during an investigatory stop. The trial court denied the motion. Defendant entered a conditional guilty plea to several drug-related charges and subsequently appealed. The court of appeals reversed, concluding (1) Defendant was detained for an unreasonably prolonged amount of time; and (2) the officers lacked reasonable suspicion to extend the duration of the stop beyond the time needed to complete a citation for a traffic violation. The Supreme Court reversed the opinion of the court of appeals and affirmed the circuit court's order denying Defendant's motion to suppress, holding (1) Defendant was detained beyond the time necessary to effectuate the purpose of the traffic stop; but (2) the prolonging of Defendant's detention was justified by at least a reasonable and articulable suspicion that she was engaged in criminal activity.
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