Motion to Suppress • Protective Frisk • Valid Traffic Stop • Authority to Tow Vehicle

Commonwealth v. Palmer, PICS Case No. 16-1014 (Pa. Super. Aug. 4, 2016) Dubow, J. (9 pages).

Police possessed a valid basis to conduct a protective frisk where appellant was ordered out of a vehicle that was to be towed pursuant to a valid traffic stop, because the vehicle was illegally parked and none of its occupants possessed a valid driver’s license. Judgment of sentence affirmed.