Commonwealth v. Dobson

Summary

The court held that police searches of Dobson's person during a traffic stop exceeded the statutory limits governing searches incident to arrest because their objective purpose was to obtain a car key and investigate a locked glove compartment, rather than to obtain evidence of the arrest offense or disarm her. The court further held that Dobson's surrender of the key did not constitute valid consent because the Commonwealth failed to show that the consent was sufficiently attenuated from the preceding coercive and unlawful searches. The order denying suppression was reversed and the case was remanded for entry of an order allowing the motion to suppress.