M.D.Pa.: Even though PA requires PC for certain traffic stops, 4A doesn’t

Pennsylvania’s requirement of probable cause for lane violations isn’t binding in federal court under the Fourth Amendment. “Accordingly, even though a Pennsylvania court may have held that Officer Sampere required probable cause to pull Defendant over for a violation of 75 Pa. C.S. § 3301(a), the traffic stop does not offend the Fourth Amendment—as interpreted by federal courts—as long as Officer Sampere possessed reasonable suspicion that such a violation occurred. Thus, this Court will hold that the traffic stop at issue here was constitutionally valid as long as Officer Sampere had at least reasonable suspicion that a violation of Pennsylvania’s Motor Vehicle Code occurred.” United States v. Langley, 2017 U.S. Dist. LEXIS 165459 (M.D. Pa. Oct. 5, 2017).

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