Page 12 - PCPA Spring 2025 Bulletin Magazine

PA CHIEFS OF POLICE ASSOCIATION
CHRIS BOYLE'S LEGAL UPDATE
Chris Boyle's Legal Update
By: Chris Boyle, Esq., Chris Boyle Law Enforcement Consulting, LLC
COMMENT: Only when the officer, by means
of physical force or show of authority, has in
some way restrained the liberty of a citizen
may we conclude that a 'seizure' has oc-
curred." The number of cases where Terry v
Ohio continues to be the focal point, some
FIFTY-PLUS years later, is amazing. If you are
going to spend precious roll call time review-
ing anything, make it Terry! Why? Because
it is implicated in 68.4% of stops (keeping
in mind that 82.1% of statistics are made up
by the author). Still, it is incredibly important
and relevant. Nice little case here on the right
of police to encounter individuals with no
suspicion whatsoever (and then work their
way up). As many of you know, my favorite
question in law enforcement remains: “What
do I have NOW?” By staying alert to chang-
ing conditions, we are better able to articu-
late what exactly we had, and WHEN we had
it. Terry requires reasonable suspicion, and
that’s how our intrepid law enforcer landed
up in this case, working all the way up to
probable cause. Nicely done!
United States v. Williams
Christopher P. Boyle, Esq.
LT. CHRISTOPHER BOYLE #125 (RET.)
is a fifth-generation Police Officer and
attorney. He spent the first sixteen
years of his professional life with the
Philadelphia Police Department, retiring
as a Lieutenant. The next sixteen years
were spent training, consulting for, and
defending Police Officers and their
Departments as a Trial Attorney and Law
Enforcement Expert. In 2020, Chris formed
“Chris Boyle Law Enforcement Consulting,
LLC” to provide training, subject matter
expertise and consultation services to law
enforcement and the legal profession. He
is a nationally recognized law enforcement
expert, frequently called upon to deliver
seminars and other training on a variety of
topics. He is also a proud member of the
Pennsylvania Chiefs of Police Association
who can be reached at: ChrisBoyle125@
ChrisBoyleConsulting. com or (215) 919-
7879. The material in this law alert has
been prepared by Chris Boyle. It is solely
intended to provide information on recent
legal developments and is not intended to
provide legal advice for a specific situation
or to create an attorney-client relationship.
United States Court of Appeals for the Third Circuit
January 15, 2025, Filed
No. 23-2980
UNITED STATES OF AMERICA v. LAQUAN WILLIAMS,
Appellant
Opinion
[*1] On Appeal from the United States District Court for
the Western District of Pennsylvania (D.C. Criminal No.
2:21-cr-00384-001)
District Judge: Honorable William S. Stickman, IV
______________
Submitted Under Third Circuit L.A.R. 34.1(a)
November 15, 2024
Before: RESTREPO, MONTGOMERY-REEVES, and
AMBRO, Circuit Judges.
(Opinion filed: January 15, 2025)
______________
OPINION*
______________
MONTGOMERY-REEVES, Circuit Judge.
LaQuan Williams appeals from his judgment of conviction,
arguing that the
District Court erred in denying his motion to suppress
certain evidence. According to Williams, the evidence
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