Single hand-to-hand transaction on the street not probable cause of anything

Single passing of money for some small object did not amount to probable cause or reasonable suspicion. Court distinguishes cases with multiple exchanges. Commonwealth v. Dunlap, 596 Pa. 147, 941 A.2d 671 (2007):

We begin by reaffirming the premise that “every commercial transaction between citizens on a street corner when unidentified property is involved does not give rise to probable cause ….” Lawson, 454 Pa. at 29, 309 A.2d at 394. First, we find that this case is immediately distinguishable from Lawson. In that case, officers observed three separate transactions. In each transaction, a random individual would approach Lawson and hand him currency. Lawson would then retreat to where his wife was located and retrieve an object, which he would then hand to the purchaser. Id. at 25-26, 309 A.2d at 392-93. After observing the multiple transactions, the officers became suspicious and approached the Lawsons. They, undoubtedly fearing apprehension, fled into a local bar. Id. In the case at bar, Officer Devlin observed only a single transaction, not multiple, complex transactions like in Lawson. Additionally, Appellant made no attempt to flee upon police intervention as Lawson and his wife did.

Arrest warrant permitted entry when defendant, after being stopped in his driveway for a traffic offense, fled inside. State v. Hart, 2007 Ohio 7162, 2007 Ohio App. LEXIS 6262 (2d Dist. December 28, 2007).*

Defendant consented to the police search, and the officers did not exceed the scope of the consent, and it was all harmless anyway. State v. Frye, 2007 Ohio 7111, 2007 Ohio App. LEXIS 6218 (5th Dist. December 26, 2007).*