Commonwealth v. Anderson, G., Aplt.

Summary

The Court held that evidence showing only that a vehicle was registered to someone other than its driver does not satisfy the Commonwealth's initial burden to show that the driver lacked a reasonable expectation of privacy. Because nonownership does not establish unlawful possession or lack of control, the registration evidence alone could not shift the burden of persuasion to Anderson. The Court reversed the Superior Court and remanded for consideration of the totality of the circumstances and other suppression issues left unresolved below.