Judge Rules “Hot Pursuit” Justified DUI Stop Outside Jurisdiction
Posted in Centre County DUI,Fourth Amendment on July 17, 2025
In Commonwealth v. Lee, CP-14-CR-1136-2024, the Centre County Court of Common Pleas ruled that a Bellefonte police officer lawfully stopped a suspected drunk driver outside of her jurisdiction under Pennsylvania’s Municipal Police Jurisdiction Act (MPJA). This case provides important guidance for anyone facing DUI charges in Pennsylvania, especially when questions arise about whether officers acted beyond their legal authority.
Facts of the DUI Case
Lee was charged with DUI – General Impairment (2nd offense) under 75 Pa.C.S. § 3802(a)(1) after a 911 caller reported a black Ford F-150 swerving dangerously through Bellefonte. The caller, a known civilian informant, remained on the phone and continued to update dispatch with the truck’s location, direction, and behavior. Two Bellefonte Borough police officers responded. One of the officers eventually located the truck in Milesburg—1.2 miles outside her jurisdiction—and conducted a traffic stop after observing additional Vehicle Code violations, including crossing the white line and failing to signal.
Legal Challenge Under MPJA
The defense filed a Motion to Suppress arguing that the officer lacked legal authority to conduct the stop outisde of her jurisdiction. Under 42 Pa.C.S. § 8953(a), officers are typically confined to their primary jurisdiction unless a specific exception applies.
The Commonwealth argued the “hot pursuit” exception applied. This exception allows officers to cross jurisdictional lines when they are immediately and continuously pursuing a suspect based on probable cause that an offense occurred within their jurisdiction.
Court’s Ruling: “Hot Pursuit” Applies
The court agreed with the Commonwealth, finding the following:
The officers began pursuing the suspect immediately upon dispatch and continued tracking the vehicle continuously and without interruption.
The 911 caller provided detailed, real-time updates, including vehicle description, behavior, and location.
Officer Neideigh observed additional traffic violations, strengthening the case for reasonable suspicion and probable cause.
Importantly, the court noted that the MPJA’s hot pursuit exception does not require the officer to personally witness a violation. Citizen reports can form a sufficient basis for pursuit.
Even If It Was a Technical Violation, Suppression Not Justified
The judge also held that—even if the stop technically violated the MPJA—it did not warrant suppression of the evidence. Applying the three-part test from Commonwealth v. Eakin, 324 A.3d 591 (Pa. Super. 2024), the court ruled:
Intrusiveness: The stop and blood test were intrusive.
Deviation from MPJA: Minimal, since officers acted in good faith.
Prejudice to Defendant: None—officers would have found the vehicle regardless, due to the active citizen report.
The judge emphasized the public safety goals of the MPJA, quoting Commonwealth v. Peters, 965 A.2d 222 (Pa. 2009), noting the law is not meant to “erect impenetrable jurisdictional walls benefitting only criminals.”
What This Means for DUI Defense in Pennsylvania
This case highlights a common issue in DUI arrests: police jurisdiction. If you were stopped by an officer from another borough or township, your case may still be lawful under the MPJA—particularly if the stop followed continuous tracking or “hot pursuit.”
However, each DUI case is unique, and suppression may still be appropriate in other circumstances. An experienced Pennsylvania DUI defense attorney can evaluate whether your rights were violated under state or constitutional law.
Contact a Centre County DUI Defense Lawyer
If you’re facing DUI charges in Centre County, State College, Bellefonte, or anywhere in Pennsylvania, contact a skilled defense attorney to protect your rights. Legal motions—such as motions to suppress evidence—can be powerful tools in fighting DUI charges. Attorney Jason Dunkle successfully obtained the suppression of DUI evidence after in a case in which the State College Police made a warrantless entry into the client’s residence to arrest him. For more info about the case, click here.
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.