Commonwealth v. Foster, J., Aplt.
CourtSupreme Court of Pennsylvania
Date FiledMay 18, 2026
Docket12 WAP 2024
JudgeDougherty, Kevin M.; Mundy, Sallie; Donohue, Christine; Wecht, David N.
StatusPublished
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Full Opinion
[J-22-2025] [MO: Dougherty, J.]
IN THE SUPREME COURT OF PENNSYLVANIA
WESTERN DISTRICT
COMMONWEALTH OF PENNSYLVANIA, : No. 12 WAP 2024
:
Appellee : Appeal from the Order of the
: Superior Court entered July 17,
: 2023, at No. 619 WDA 2022,
v. : affirming the Judgment of Sentence
: of the Court of Common Pleas of
: Allegheny County entered January
JAMAR FOSTER, : 5, 2022, at No. CP-02-CR-0013992-
: 2019.
Appellant :
: ARGUED: April 9, 2025
DISSENTING OPINION
JUSTICE WECHT DECIDED: MAY 18, 2026
I join Justice Donohue’s Dissenting Opinion in all respects, save one. I cannot
acquiesce in perpetuating the legal fiction that the purported “high crime” character of a
neighborhood can (or should) be a relevant factor in a reasonable suspicion or probable
cause determination. 1 As I have explained elsewhere, 2 while police investigatory,
staffing, patrol, and response decisions may (and routinely do) relate to judgments and
1 See Diss. Op. at 4-5.
2 See Commonwealth v. Lewis, 343 A.3d 1016, 1054 (Pa. 2025) (Wecht, J.,
concurring and dissenting) (acknowledging that “[p]olice officers’ intuition and experience
are properly used every day—indeed every hour and minute—to make choices and
decisions about patrol priorities, physical and electronic surveillance, resource allocation,
and all manner of other proper law enforcement activities,” but explaining that such
practices cannot be a substitute for individualized reasonable suspicion that is predicated
and developed upon the suspect’s conduct, as observed by the law enforcement officer);
see also Commonwealth v. Dobson, 307 A.3d 612, 625 (Pa. 2024) (Wecht, J., Opinion in
Support of Reversal); Commonwealth v. Galloway¸ 284 A.3d 870, 875 (Pa. 2022) (Wecht,
J., dissenting).
experience concerning incidence of criminal activity in particular areas, such decisions do
not equate to individualized reasonable suspicion. Like police judgments and experience
concerning crime rates in areas patrolled, technologies like ShotSpotter can form
important and useful tools in police investigations. What they cannot do is substitute for
the individualized reasonable suspicion that our Constitutions require. The Court should
differentiate between investigatory tools and evidentiary requirements.
[J-22-2025] [MO: Dougherty, J.] - 2