A juvenile probation officer's warrantless search of a probationer's bedroom must be supported by a reasonable suspicion that the juvenile possessed contraband or was in violation of the conditions of his or her supervision.

A warrantless search will be presumed unreasonable except where the circumstances fit into an established exception, such as a search incident to arrest.

Evidence that was abandoned as a direct and proximate result of an illegal detention by the police should be suppressed. The fact that a defendant may not be attempting to go anywhere at the time he or she is "ordered" to stay in a car does not mean that the defendant is incapable of being seized. There is "no authority that states that a person must be in transit or display a desire to leave a scene in order for that person to be seized."

A suspect's unprovoked flight in a high crime area is sufficient to create reasonable suspicion to justify a Terry stop. The appropriate time to consider whether the police have reasonable suspicion is at the point when the seizure of the defendant is effectuated.

Contraband discarded by a person fleeing a police officer is the fruit of an illegal "seizure" when the officer possessed neither probable cause to arrest the individual nor reasonable suspicion to stop the individual and conduct a Terry frisk. Police pursuit of a suspect is a seizure under the Pennsylvania Constitution, and therefore requires probable cause or reasonable suspicion.

When it is not immediately apparent that a soft bulge is contraband, a search of the bulge is outside the scope of Terry and Dickerson. An officer must do more than testify as to a general suspicion that a bulge may have been contraband and offer, as substantiation, that the bulge was soft.

The "immediately apparent" requirement of the plain feel doctrine is not met when an officer conducting a Terry frisk merely feels and recognizes by touch an object that could be used to hold either legal or illegal substances (e.g., a cigar or pill bottle), even when the officer has previously seen others use that object to carry or ingest drugs.

A zip-lock baggie is not per se contraband nor is it immediately apparent to an officer who feels such a baggie during the course of a lawful Terry frisk that it contains contraband.

Frisks must be based on articulable, specific facts that lead an officer to believe that a defendant might be armed or dangerous. An officer's general statement that the frisk is being performed for safety does not provide a sufficient basis for conducting a frisk incident to an investigatory stop.

No Pennsylvania court has adopted a per se rule allowing the frisk of an arrestee's companion, or an "automatic companion rule." An arrestee's companion may be stopped and frisked when there is reasonable suspicion that the companion is armed and dangerous. It is inherently reasonable for a law enforcement officer to briefly detain and direct the movement of an arrestee's companion, regardless of whether reasonable suspicion exists that the companion is involved in criminal activity. But in cases involving the frisk of an arrestee's companion, the sole question is whether the police officer had a reasonable belief that the companion was armed and dangerous.