PA: Whether an area is “high crime” for RS purposes needs to be evaluated with caution

“We granted discretionary review to consider the quantum of evidence necessary to prove an area is high in crime, such that a suppression court may properly consider that fact among the totality of the circumstances when assessing whether reasonable suspicion existed at the time of a stop. More specifically, appellant Anthony Lewis asks us to impose a strict, multi-element test on the Commonwealth anytime it wishes to designate the scene of a stop as a “high-crime area.” We decline the invitation. For the reasons that follow, we leave it to the discretion of suppression courts to determine whether the Commonwealth has proven an area is high in crime, as well as how much weight to assign to this factor. In so doing, we urge suppression courts to review high-crime area designations with caution and emphasize that merely intoning buzzwords is never sufficient to prove an area is high in crime. Applying these principles to this case, we find the evidence supports the suppression court’s conclusion that the scene of the stop was a high-crime area. We further hold the police had reasonable suspicion to conduct an investigatory detention based on the totality of the circumstances, including the high-crime nature of the area. Accordingly, we affirm the order of the Superior Court upholding the denial of suppression.” Commonwealth v. Lewis, 2025 Pa. LEXIS 1498 (Sep. 25, 2025).