Opinion

Commonwealth v. Salter

  • 2015 Pa. Super. 166
  • 121 A.3d 987
  • 2015 Pa. Super. LEXIS 447
Court
Superior Court of Pennsylvania
Filed
Aug 4, 2015
Status
Published
Author
Shogan
On the bench
Elliott, Shogan, Stabile
Cited by
126 cases

holding that violation of 75 Pa.C.S. § 4303, lighting requirements, required probable cause for stop, as “[n]othing more needed to be determined by [the o]fficer ... upon a stop to verify that the plate light was not operating”

How later courts described this case

  • holding that violation of 75 Pa.C.S. § 4303, lighting requirements, required probable cause for stop, as “[n]othing more needed to be determined by [the o]fficer ... upon a stop to verify that the plate light was not operating”
  • concluding that officer had probable cause to arrest appellant for DUI where appellant had glassy eyes, had an odor of alcohol, admitted that she had two glasses of alcohol, and performed poorly on the field sobriety tests
  • concluding that the officer had probable cause to stop the defendant’s vehicle where officer could not see defendant’s registration plate from a distance of 50 feet
  • finding probable cause to arrest for DUI where driver admitted to drinking, had bloodshot and glassy eyes, and the vehicle had an odor of alcohol, despite Appellant’s speech not being slurred or his driving erratic

Written by the judges who cited it.

The opinion

CONCURRING STATEMENT BY

SHOGAN, J.:

I question whether the police officer had probable cause to conduct the traffic stop due to the officer being seventy-five feet from Appellee’s vehicle at the time he determined that the registration plate was not illuminated. The traffic regulation in question requires only that the lights “make the registration plate visible from [a] distance of 50 feet to the rear of the vehicle,” not 75 feet. See 67 Pa. Code § 175.66 (k). However, because I conclude that the officer had at least reasonable suspicion to believe that the license plate lamps were not functioning properly, the traffic stop was proper, and because I conclude that the officer had probable cause to arrest Appellee for DUI, I concur in the result reached by the Majority.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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