Page 25 - PCPA Summer 2025 Bulletin Magazine

CHRIS BOYLE'S LEGAL UPDATE
Chris Boyle's Legal Update
SUMMER 2025 BULLETIN
By: Chris Boyle, Esq., Chris Boyle Law Enforcement Consulting, LLC
COMMENT: I am always on the lookout for
a good case involving Terry v Ohio or forced
abandonment. This little nugget has both! We
should be schooling our troops on the fact
that an anonymously-provided description,
alone, is not necessarily going to be enough
for a Terry stop. We need that, PLUS. Here,
the good Sergeant was able to articulate: 1)
that he DID fit the description, AND 2) he was
blading away from him, AND 3) this was a
high crime area. All put together, it amounted
to enough reasonable suspicion for the stop.
Without all of it, this would have been a case
of forced abandonment (where an officer at-
tempts an investigative detention without
reasonable suspicion, and the turd abandons
what he is carrying as a result)! Be well and
stay safe everyone-CB
Commonwealth v. Appellant
Superior Court of Pennsylvania
April 15, 2025, Filed
No. 441 EDA 2024
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.
Neil Williams ("Williams") appeals from the judgment of
sentence imposed following his conviction for prohibited
possession of a firearm.1 He challenges the denial of his
motion to suppress. We affirm.
The Commonwealth elicited the following testimony at
Reporter
2025 Pa. Super. Unpub. LEXIS 1017 *
COMMONWEALTH OF PENNSYLVANIA v. NEIL WIL-
LIAMS Appellant
Opinion
[*1] Appeal from the Judgment of Sentence Entered
September 29, 2023 In the Court of Common Pleas of
Philadelphia County Criminal Division at No(s): CP-51-
CR-0002390-2023
BEFORE: NICHOLS, J., MURRAY, J., and LANE, J.
MEMORANDUM BY LANE, J.:FILED APRIL 15, 2025
the suppression hearing. At approximately 9:30 a.m. on
February 18, 2023, Sergeant Luke Lesko of the City of
Philadelphia Police received a radio dispatch for a reported
robbery in the 4300 block of North 8th Street, a location
known for "[a] lot of violent crime, robberies, shootings,
[and] carjackings[.]" N.T., 7/20/23, at 9-10. The report was
for a robbery "at the corner store at 8th and Bristol," and
described the actor as a "[B]lack male, black jacket, blue
hoodie and jeans."
1See 18 Pa.C.S.A. 6105(a). Williams was prohibited
from possessing a firearm due to a prior conviction for
aggravated assault. See N.T., 7/20/23, at 49 (stipulation to
prior conviction).
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