immediately apparent requirement in Pennsylvania

2022See Stevenson, 744 A.2d at 1265 (“If, after feeling the object, the officer lacks probable cause to believe that the object is contraband without conducting some further search, the immediately-apparent requirement has not been met, and the plain feel doctrine cannot justify the seizure of the object.”).

2018See Stevenson, 744 A.2d at 1268 (stating that officer’s testimony that the cardboard he felt in the defendant’s pocket was contraband as he had previously seen drugs packaged in cardboard does not meet the immediately apparent requirement); id. (noting that “[t]he mere fact that an officer has seen others use an object to package drugs, however, does not mean that once the officer feels that object during a pat-down search of a different individual, he automatically acquires probable cause to seize the object under the plain feel doctrine as something that is ‘immediately apparent’ as contraba

2020If, after feeling the object, the officer lacks probable cause to believe that the object is contraband without conducting some further search, the immediately apparent requirement has not been met and the plain feel doctrine cannot justify the seizure of the object. - 23 - Commonwealth v. Pakacki, 587 Pa. 511, 521 , 901 A.2d 983, 989 (2006) (citation and quotation omitted).

2020If, after feeling the object, the officer lacks probable cause to believe that the object is contraband without conducting some further search, the immediately apparent requirement has not been met and the plain feel doctrine cannot justify the seizure of the object. - 23 - Commonwealth v. Pakacki, 587 Pa. 511, 521 , 901 A.2d 983, 989 (2006) (citation and quotation omitted).

2025See Thompson, 985 A.2d at 935 (explaining that while an officer’s training and experience is relevant to evaluating probable cause, but an officer cannot “simply reference training and experience abstract from an explanation of their specific application to the circumstances at hand” (citation omitted)); Randolph, 151 A.3d at 183-84 (explaining the officer must demonstrate a nexus between his training and/or experience and the item at issue to establish probable cause to conduct a search); see also Saunders, 326 A.3d at 897 (explaining that the immediately apparent requirement of the plain vie

2025See Thompson, 985 A.2d at 935 (explaining that while an officer’s training and experience is - 21 - J-E03003-24 relevant to evaluating probable cause, but an officer cannot “simply reference training and experience abstract from an explanation of their specific application to the circumstances at hand” (citation omitted)); Randolph, 151 A.3d at 183-84 (explaining the officer must demonstrate a nexus between his training and/or experience and the item at issue to establish probable cause to conduct a search); see also Saunders, 326 A.3d at 897 (explaining that the immediately apparent requireme

2025See Thompson, 985 A.2d at 935 (explaining that while an officer’s training and experience is relevant to evaluating probable cause, but an officer cannot “simply reference training and experience abstract from an explanation of their specific application to the circumstances at hand” (citation omitted)); Randolph, 151 A.3d at 183-84 (explaining the officer must demonstrate a nexus between his training and/or experience and the item at issue to establish probable cause to conduct a search); see also Saunders, 326 A.3d at 897 (explaining that the immediately apparent requirement of the plain vie

2025See Thompson, 985 A.2d at 935 (explaining that while an officer’s training and experience is - 21 - J-E03003-24 relevant to evaluating probable cause, but an officer cannot “simply reference training and experience abstract from an explanation of their specific application to the circumstances at hand” (citation omitted)); Randolph, 151 A.3d at 183-84 (explaining the officer must demonstrate a nexus between his training and/or experience and the item at issue to establish probable cause to conduct a search); see also Saunders, 326 A.3d at 897 (explaining that the immediately apparent requireme

2024The immediately apparent requirement is “coextensive with probable cause.” Commonwealth v. Zhahir, 751 A.2d 1153, 1163 (Pa. 2000); see also Commonwealth v. Ellis, 662 A.2d 1043, 1049 (Pa. 1995) (“[I]t must be immediately apparent to the viewer that the object observed is incriminating evidence.

2018“If, after feeling the object, the officer lacks probable cause to believe that the object is contraband without conducting some further search, the immediately apparent requirement has not been met and the plain feel doctrine cannot justify the seizure of the object.” Thompson, 939 A.2d at 376 ; see also Commonwealth v. Zahir, 751 A.2d 1153, 1163 (Pa. 2000) (noting that an officer’s subjective belief that an item is contraband is not sufficient unless it is objectively reasonable in light of the facts and circumstances that attended the frisk).

2010Id.; see also Commonwealth v. Graham, 554 Pa. 472, 485-86 , 721 A.2d 1075, 1082 (1998).

2010Id.; see also Commonwealth v. Graham, 554 Pa. 472, 485-86 , 721 A.2d 1075, 1082 (1998).

2024The immediately apparent requirement is “coextensive with probable cause.” Commonwealth v. Zhahir, 751 A.2d 1153, 1163 (Pa. 2000); see also Commonwealth v. Ellis, 662 A.2d 1043, 1049 (Pa. 1995) (“[I]t must be immediately apparent to the viewer that the object observed is incriminating evidence.

2018See Stevenson, 744 A.2d at 1268 (stating that officer’s testimony that the cardboard he felt in the defendant’s pocket was contraband as he had previously seen drugs packaged in cardboard does not meet the immediately apparent requirement); id. (noting that “[t]he mere fact that an officer has seen others use an object to package drugs, however, does not mean that once the officer feels that object during a pat-down search of a different individual, he automatically acquires probable cause to seize the object under the plain feel doctrine as something that is ‘immediately apparent’ as contraba

2018See Stevenson, 744 A.2d at 1268 (stating that officer’s testimony that the cardboard he felt in the defendant’s pocket was contraband as he had previously seen drugs packaged in cardboard does not meet the immediately apparent requirement); id. (noting that “[t]he mere fact that an officer has seen others use an object to package drugs, however, does not mean that once the officer feels that object during a pat-down search of a different individual, he automatically acquires probable cause to seize the object under the plain feel doctrine as something that is ‘immediately apparent’ as contraba

2000See Dickerson, 508 U.S. at 377-78 , 113 S.Ct. at 2138-39 (when officer felt small hard object wrapped in plastic and determined it was crack cocaine only after conducting further search, i.e. squeezing and manipulating object, seizure of object was not justified by plain feel doctrine). 4 Accordingly, the drugs recovered from R.A.’s jacket must be suppressed.

2000See Dickerson, 508 U.S. at 377-78 , 113 S.Ct. at 2138-39 (when officer felt small hard object wrapped in plastic and determined it was crack cocaine only after conducting further search, i.e. squeezing and manipulating object, seizure of object was not justified by plain feel doctrine). 4 Accordingly, the drugs recovered from R.A.’s jacket must be suppressed.

2000In Commonwealth v. Fink, a case which examined the immediately apparent requirement of the plain feel doctrine, the arresting officer testified that during a pat-down search of the defendant he felt an object resembling “a regular smoking pipe without the stem.” 700 A.2d 447, 450 (Pa.Super.1997), appeal denied, 552 Pa. 694 , 716 A.2d 1247 (1998).

2000In Commonwealth v. Fink, a case which examined the immediately apparent requirement of the plain feel doctrine, the arresting officer testified that during a pat-down search of *1266 the defendant he felt an object resembling "a regular smoking pipe without the stem." 700 A.2d 447, 450 (Pa.Super.1997), appeal denied, 552 Pa. 694 , 716 A.2d 1247 (1998).