Pennsylvania v. Livingstone (majority)Annotate this Case
The Pennsylvania Supreme Court granted review in this matter to consider whether Appellant Victoria Livingstone, who was in a stopped vehicle on the side of the road, was subjected to an investigatory detention without reasonable suspicion of criminal activity when a police officer, checking to see if she needed help, pulled his patrol car, with its emergency lights activated, alongside her vehicle. The Court determined Appellant was subjected to an illegal investigatory detention based on these facts. Furthermore, although the Court recognized the public servant “exception” to the warrant requirement under the community caretaking doctrine, which in certain circumstances will permit a warrantless seizure, it concluded the doctrine did not justify the detention of Appellant under the facts of this case. Thus, the Superior Court erred in affirming the trial court's denial of Appellant’s motion to suppress evidence obtained as a result of her illegal investigatory detention, and the Superior Court's decision was reversed. The matter was remanded for further proceedings.