Page 16 - PCPA Winter 2024 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: I frequently get asked
about stopping a vehicle based on the
owner of the vehicle coming back as
a suspended license based on a LPR
hit. Nice case here addressing exactly
that. So long as we don’t have evi-
dence that this is NOT the suspended
driver, the US Supreme Court says
we are good to go. Also, though, keep
in mind that sometimes reasonable
suspicion raises its pretty little head
while we are walking up, so don’t as-
sume the day is lost if the driver is not
the suspended owner. Just keep ask-
ing your self, “What do I have NOW!”
Be well and stay safe everyone –
Chris “The Chump” Boyle
Commonwealth Appellant v. Sullivan
Superior Court of Pennsylvania
October 25, 2024, Filed
No. 2380 EDA 2023
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.
Reporter
2024 Pa. Super. Unpub. LEXIS 2674
*
COMMONWEALTH OF PENNSYLVANIA Appellant v.
BRIAN SULLIVAN
Opinion
[*1] Appeal from the Order Entered August 28, 2023
In the Court of Common Pleas of Philadelphia County
Criminal Division at No: CP-51-CR-0000975-2023
BEFORE: STABILE, J., KING, J., and COLINS, J.*
MEMORANDUM BY STABILE, J.:FILED OCTOBER 25,
2024
The Commonwealth of Pennsylvania appeals from the
August 28, 2023,
order granting Appellee Brian Sullivan’s motion to
suppress evidence. Upon review, we reverse and re-
mand.
The trial court summarized the facts adduced at the
suppression hearing as follows:
Philadelphia Police Officer Dave Dohan (hereinafter
“Officer Dohan”) testified at the suppression hearing.
Officer Dohan indicated on December 8, 2022, at about
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