Commonwealth v. Johnson

The issue presented is whether a protective sweep of an automobile for weapons was justified in the instant case. The officers making this ordinary traffic stop observed no furtive movements suggesting the concealment of weapons by either the defendant, Jeromie Johnson, who was driving, or his passenger. The officers were also not aware of any reports of weapons, or any criminal history of violence or weapons possession by the occupants of the car, when they searched the *337automobile.1 We therefore conclude that the protective sweep of the automobile was not justified, and that the defendant’s…