On January 27, 2010, Troopers Yingst and Rudella saw Joseph driving recklessly on Interstate Highway 83 in Cumberland County, Pennsylvania. Joseph was traveling at about 77mph in a fifty-five mile per hour zone, and was weaving across the fog lines into other lanes of traffic. As a result, the troopers stopped Joseph's car.
During the stop, the troopers asked Joseph where he was coming from, to which he initially responded that it was none of the officers f---ing business. Later, he explained that he was coming from a gas station where he had purchased and ingested a "sex pill" and a cappuccino. Neither answer was consistent with the troopers observations: instead, they believed Joseph had entered the Interstate from the Allison Hill area of Cumberland County, which is known for high drug activity.
During the stop, the officers also observed several items in plain-view in Joseph's car that they associated with drugs: multiple air-fresheners, potpourri, three bars of soap, and a wrapped blunt cigar. When Trooper Yingst returned to the police car to write Joseph a warning, he discovered that Joseph had a significant history of drug use, including convictions for possession with intent to deliver.
Yingst gave the warning to Joseph, explained it to him, and then told him he was free to go. He began to walk away, then turned and asked Joseph if he would mind answering some additional questions, specifically, whether he was transporting guns, drugs, or large amounts of U.S. currency. Joseph became agitated in response to the question, and called the trooper a f---ing racist.
Thereafter, Yingst informed Joseph that he was still free to go but, based on his reasonable suspicion of criminal activity, the troopers intended to keep the car until a warrant could be obtained for its search. This agitated Joseph further and, in response to his behavior, the troopers drew their tasers. Joseph then fled. A warrant was, ultimately, obtained, and a search of the car revealed marijuana and a handgun. Joseph was arrested, tried, convicted, and appealed.
The Superior Court concluded that the initial stop was proper, but the seizure of Joseph's car on reasonable suspicion was unjustified. Instead, the Court held that reasonable suspicion - which is sufficient to support a brief search and seizure of a person in the Terry stop-and-frisk context - is insufficient to detain a car for the amount of time necessary to obtain a warrant.
The Court underscored its reasoning by pointing to the fact that a warrant cannot issue on reasonable suspicion alone; instead, a warrant requires a showing of probable cause. Therefore, a seizure based on reasonable suspicion for the sole purpose of obtaining a warrant is definitionally inappropriate.
As a result of their holding, the Court vacated Joseph's conviction and remanded for further proceedings.
