PA: Blocking def’s vehicle showed he wasn’t free to leave, and it lacked RS

“Having determined that Officer Byrne effectuated an investigatory detention upon pulling behind Appellant’s vehicle, and that such detention was not supported by a reasonable suspicion that criminal activity was afoot nor excused from constitutional warrant requirements by the public servant exception of the community caretaking doctrine, we conclude that the trial court erred in denying Appellant’s motion to suppress all evidence obtained as a result of the unsupported investigatory detention, including the results of the field sobriety tests, preliminary breath test, and the chemical test of his breath which showed a blood alcohol concentration of .161 percent.” Commonwealth v. Hampton, 2019 PA Super 38, 2019 Pa. Super. LEXIS 119 (Feb. 12, 2019).*