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Commonwealth v. Gregory Philip Kendall 2009 PA Super 100 (5/29/2009)

Topic: Reasonable Suspicion – Automobile Stop – Officer’s Duty to Aid

Summary: Where an officer approaches a vehicle to render aid, the incident is a mere encounter and reasonable suspicion is not necessary.

Illustration: While driving on a desolate road in the middle of the night, Defendant pulled over. Although the officer was following Defendant for a few minutes, no motor vehicle violations were observed. The police officer asserted that he pulled over to see if everything was ok. The police do not need reasonable suspicion when they are acting on their duty to render aid. Therefore, the Superior Court found that this was not an investigative detention/stop and reasonable suspicion was not needed.