Judge Denies Suppression Request in Centre County DUI

Posted in Centre County DUI on June 28, 2025

DUI Traffic Stop in Centre County: What Happened?

In May 2023, police in Spring Township, PA, received a radio report about a recklessly driven silver Chevrolet truck with tinted windows. Minutes later, an officer spotted a similar vehicle and followed it. The driver pulled to the side of the road without activating a turn signal and did not activate his hazard lights. The truck was stopped the truck partially in the roadway. The driver exited the truck and then crawled underneath the front of the vehicle while it was still running. The officer stopped behind the truck, but the officer did NOT activate his overhead lights, so this was not a traffic stop. Concerned for safety, the officer approached the truck. He talked to driver. The driver advised that he was fixing the truck, but the driver was lying face down. During the interaction, the officer noticed:

✅ Slurred speech
✅ Bloodshot, glassy eyes
✅ Strong odor of alcohol

When Mr. Bunton refused to come out from under the vehicle, backup arrived. Officers eventually removed him and arrested him for suspected DUI in Pennsylvania. During the incident, officers opened the truck door, turned off the engine, and saw a tumbler in plain view, along with further signs of alcohol use.

Motion to Suppress Evidence: Were the Driver’s Rights Violated?

The driver was charged with a DUI.  The man’s DUI defense attorney filed a motion to suppress evidence, arguing:

• He was unlawfully detained without reasonable suspicion.

• His truck was searched without a valid warrant or exception.

The Centre County Court denied the motion, ruling that the police acted lawfully.

What Pennsylvania Drivers Can Learn About DUI Stops and Vehicle Searches

1. What Is a Legal Police Encounter in Pennsylvania?

Police are allowed to approach your vehicle and ask questions — this is called a mere encounter. It doesn’t require reasonable suspicion or probable cause. With a mere encounter, a person is permitted to ignore the police officer and leave the area.

NOTE: What started as a mere encounter can become a detention. The officer may assert authority and tell a person that they cannot leave unless they identify themselves. In such a scenario, in order for the detention to be lawful, the officer must have reasonable suspicion to believe that the person was engaged in criminal activity.

In this case, the officer’s initial approach, asking if he was okay, was considered a legal mere encounter.

2. Community Caretaking Exception in PA

Under Pennsylvania law, officers can check on individuals for safety reasons, even if no crime is suspected. This is known as the community caretaking doctrine. The officer testified that Mr. Bunton’s behavior — stopping in the roadway, crawling under a running vehicle — raised legitimate safety concerns, justifying the officer’s actions.

NOTE: The police sometimes abuse or misused the community caretaking function. In a prior State College DUI case, the police made a warrantless entry in a client’s residence because they claimed that they suspected client was suffering from a diabetic incident. The Pennsylvania Superior Court ruled that the police had violated my client’s constitutional rights and granted the suppression of evidence.

3. When Does a DUI Stop Become an Investigative Detention?

The Centre County court stated that the police-citizen encounter did change from a mere encounter to an investigative detention when the officer called for backup and repeatedly told the driver to get out from under the truck. The Court also stated that the officer had sufficient reasonable suspicion of criminal activity when:

✔ The officer smelled alcohol
✔ Mr. Bunton’s speech was slurred
✔ He refused to cooperate

At that point, the officer had reasonable suspicion for a DUI investigation in Pennsylvania, which makes the detention and further investigation legal.

4. Vehicle Search and Inevitable Discovery in Pennsylvania DUI Cases

Although police opened the vehicle door without a warrant, the court ruled that:

• The vehicle was blocking the roadway.

• The engine was running.

• The vehicle needed to be towed.

Under the inevitable discovery doctrine, officers would have lawfully discovered evidence like the tumbler and odor of alcohol during standard towing procedures.

Can Evidence Be Suppressed After a DUI Arrest in Pennsylvania?

Yes, in some cases. But as this ruling shows, courts often uphold vehicle searches and DUI arrests if police follow proper procedures or valid exceptions apply.

Common reasons a motion to suppress DUI evidence in PA may succeed include:

• Lack of reasonable suspicion for the stop

• Illegal vehicle search without a warrant or valid exception

• DUI lawyers may seek suppression of blood or breath test evidence if the officer did not have probable cause to lawfully arrest

Arrested for DUI in Pennsylvania? Know Your Rights.

If you’ve been charged with DUI in Pennsylvania, or believe police violated your rights during a vehicle search or traffic stop, it’s essential to speak with an experienced Pennsylvania DUI lawyer.

An attorney can:

✅ Review whether the police stop was legal
✅ Challenge illegal searches of your vehicle
✅ File motions to suppress evidence
✅ Fight to protect your license and freedom

For a free case review, contact JD Law by email or leave a message at (814) 689-9139. Email is the preferred method of communication, as phone calls are directed to voicemail due to the high volume of spam and unsolicited calls.