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Appellate panel questions whether Snapchat image justified searches and removal of occupants in juvenile stop
Summary
Defense argued officers lacked reasonable suspicion to expand a traffic stop and search a vehicle after a live Snapchat photo showed a firearm; the Commonwealth said the close timing of live posts, identification of occupants and rapid sequence of events supported officers' actions.
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In a juvenile-case appeal, the panel considered whether officers lawfully expanded a traffic stop and ordered occupants out after viewing a live Snapchat story that, according to officers, briefly showed what appeared to be a loaded firearm.
Defense counsel Jason Tautjas argued the Snapchat picture alone did not provide particularized suspicion that a firearm was improperly stored in the vehicle or that a specific occupant possessed it. "We don't know whether it is a firearm under the law at this point," Tautjas said, noting there was nothing in the record confirming the image showed a loaded weapon or that the account owner was present.
The Commonwealth responded that the sequence of live photos—one showing a known individual ("DC"), minutes later a live photo of what a trained officer believed to be a loaded, improperly stored firearm, followed shortly by a live photo of the juvenile—created a temporal nexus supporting reasonable suspicion. Prosecutors emphasized rapid developments: officers saw nine people leave the gym and enter the Cadillac near where the posting occurred and then briefly observed what they believed to be a firearm handle in plain view as an occupant exited.
The panel pressed on practical limits: how long the Snapchat post was live, whether it showed a loaded firearm, whether the officers had individualized suspicion to order nine occupants out and conduct bag frisks, and whether body-worn camera footage supported the judge's factual findings about the search's timing. The defense argued that patting and searching bags without a particularized basis constituted an impermissible search of the vehicle.
The court took the argument under advisement.

