Commonwealth v. Robinson

Summary

The court held that police unlawfully ordered Robinson out of his vehicle during a routine traffic stop because the circumstances supplied neither an objectively reasonable safety concern nor reasonable suspicion of criminal activity. His consent to search, given less than two minutes later without intervening circumstances, was insufficiently attenuated from the unlawful seizure, so the drugs, firearm, and ammunition should have been suppressed. Admission of that evidence was not harmless beyond a reasonable doubt; the ammunition conviction could not be retried because the Commonwealth presented no evidence that Robinson lacked an FID card, while the remaining charges were remanded for further proceedings.