Commonwealth of Pennsylvania v. Jesse Noel Heisey

Commonwealth of Pennsylvania v. Jesse Noel Heisey

Criminal Action-Constitutional Law-Omnibus Pretrial Motion-Suppression of Evidence-Drug Related Charges-Vehicle Stop-Custodial Interrogation-Miranda Warnings-Voluntary or Spontaneous Utterance-Request for K-9 Unit-Detention for Investigation-Reasonable Suspicion

Jesse Noel Heisey (“Defendant”) incurred multiple drug related charges after the vehicle he was operated was stopped due to invalid state inspection stickers.  During the stop, the law enforcement officer noted that the claimant appeared jittery and elevated and was unable to provide insurance information, asking the law enforcement officer “…to give me a break.”  Defendant provided inconsistent information about his travel destination.  Observing two (2) lock boxes and Crown Royal bags inside of the vehicle, the law enforcement officer requested permission to search the vehicle, which Defendant refused.  When the law enforcement officer stated that he would procure a K-9 unit, a lanyard around Defendant’s neck spilled a substance that appeared to be crack cocaine with Defendant stating, “…search the f****** thing.”  Contraband was located when the vehicle was searched.  Defendant filed an Omnibus Pretrial Motion seeking suppression of statements made before he was advised of warnings pursuant to Miranda v. Arizona, 384 U.S. 436 (1966), and asserting that the law enforcement officer did not have reasonable suspicion to detain the vehicle for inspection by a K-9 unit.

1.  Miranda, supra, provides that the Fifth Amendment to the United States Constitution requires that warnings must be provided by a law enforcement officer to any custodial detainee before questioning.

2.  Statements obtained during a custodial interrogation are presumed to be involuntary unless Miranda warnings first have been provided.

3.  A custodial interrogation is questioning initiated by law enforcement after a person has been taken into custody or otherwise deprived of his or her freedom of action in any significant way.

 4.  Voluntary or spontaneous utterances are admissible without prior administration of Miranda warnings.

5.  Interrogation refers not only to express questioning, but also to any words or actions on the part of law enforcement that law enforcement should know reasonably are likely to elicit an incriminating response from the suspect.

6.  A totality of the circumstances test can be used to determine whether a custodial interrogation has occurred.

7.  Since Defendant was not placed in handcuffs until law enforcement determined that the contents that spilled from his lanyard looked like crack cocaine, Defendant never physically was restrained prior to that time and law enforcement never displayed a weapon, Miranda warnings were not necessary for any statements made during the investigative detention, as he was not yet in custody.

8.  Statements made prior to the spilling of the substance from the lanyard are admissible, while statements made after the claimant had been handcuffed prior to the provision of Miranda warnings necessitate suppression. 

9.  Only reasonable suspicion of criminality is needed to detain an individual for investigation.

10.  Reasonable suspicion occurs when an officer combines current observations with prior experiences reasonably to conclude that there is criminal activity present and the person detained is involved in that activity.

11.  A totality of the circumstances test is undertaken to determine whether reasonable suspicion of criminal activity exists to support detention for investigation.

12.  Where the law enforcement officer indicated that he had reasonable suspicion to request the services of a K-9 unit because Defendant’s mannerisms of nervousness and elevation were suspicious, he viewed two (2) Crown Royal bags and lock boxes in the vehicle that in his experience often contain drugs when carried in vehicles, Defendant provided inconsistent information about his travel destination and Defendant acknowledged that he is a Methadone maintenance user, the testimony of the law enforcement officer provides more than sufficient evidence establishing reasonable suspicion of criminal activity supporting the request for a K-9 unit.

L.C.C.C.P. No. CP-38-CR-1274-2024, Opinion by Bradford H. Charles, Judge, August 27, 2025.