The Supreme Court analyzed a case where Victoria Livingstone was detained by a trooper who had no reasonable suspicion of any criminal activity. The trooper had pulled alongside Victoria's car and turned on emergency lights, which violated her Fourth Amendment rights. The Commonwealth argued that the trooper was acting to assist her under the community caretaking exception, but the Court established a two-part test to determine if such actions by an officer are justified.
The relevant facts to the court's analysis were that the trooper did not have any specific, objective, and articulable facts to suggest that Victoria needed help. Therefore, the trooper's seizure of Victoria was not justified and the evidence obtained should have been suppressed.
Commonwealth v. Livingstone (2017)
Supreme Court of Pennsylvania
174 A.3d 609
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