Background
[J-62-2025] IN THE SUPREME COURT OF PENNSYLVANIA EASTERN DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ. COMMONWEALTH OF PENNSYLVANIA, : No. 62 EAP 2024 : Appellee : Appeal from the Order of the : Superior Court at No. 62 EDA 2023 : entered on February 16, 2024, v. : affirming the Order of the : Philadelphia County Court of : Common Pleas at No. MC-51-CR- QUADIR STEADLY, : 0016266-2021, entered on : November 28, 2022 Appellant : : ARGUED: September 9, 2025 OPINION JUSTICE DONOHUE DECIDED: July 21, 2026 Philadelphia Police Officer Corey Moore lawfully stopped Quadir Steadly for a minor Motor Vehicle Code violation, during which Officer Moore attempted to arrest Steadly after learning from a dispatcher that two bench warrants had been issued in Steadly’s name. To effectuate the arrest, Officer Moore required assistance from several additional officers to overcome Steadly’s resistance.
Background The Commonwealth charged Steadly with recklessly endangering another person (“REAP”) and resisting arrest.2 At a bench trial held in Philadelphia Municipal Court, the Commonwealth presented Officer Moore’s testimony and bodycam footage of the incident. Steadly testified in his own defense and presented unrebutted character evidence by stipulation. The evidence adduced at trial was as follows. Officer Moore testified that at approximately 7:15 p.m. on August 30, 2021, he pulled Steadly over because of an illegally tinted windshield.3 N.T., 4/1/2022, at 10. Steadly was unable to provide Officer Moore with his license, registration, or proof of insurance, but instead verbally provided the officer with identity information. Officer Moore returned to his police cruiser to enter that information into his Mobile Data Terminal (“MDT”), from which the officer learned that there were two bench warrants that had been issued in Steadly’s name. Steadly’s counsel lodged a best-evidence objection to Officer Moore’s testimony regarding the content of the MDT database.4 Id. at 12-13. The court sustained the 2 18 Pa.C.S. §§ 2705, 5104. 3 See 75 Pa.C.S. § 4524(E). The Commonwealth never charged Steadly with a violation of Section 4524. 4 “An original writing, recording, or photograph is required in order to prove its content unless these rules, other rules prescribed by the Supreme Court, or a statute provides otherwise.” Pa.R.E. 1002. [J-62-2025] – 2 objection insofar as the testimony was being offered to prove the existence or validity of the warrants.
The Court’s Holding
conclusion that Biagini’s behavior, including a vulgar-filled tirade, did not amount to disorderly conduct or public drunkenness and thus, “Biagini had committed no action which justified his immediate apprehension”); Commonwealth v. Hock, 728 A.2d 943, 947 (Pa. 1999) (holding that “Hock's remark did not constitute disorderly conduct, and the officer thus lacked probable cause to arrest her for that offense”). This, however, is not what occurred here. In both Biagini and Hock, there was no lawful arrest due to the officer’s misinterpretation of the criminal statute, and thus, the defendant could not have been guilty of resisting a lawful arrest. Without belaboring the point, in this case, the arrest was based on the officer’s knowledge of two outstanding bench warrants in Steadly’s name. In other words, there is a material distinction between an on-the-spot assessment of potential criminal behavior and a scenario in which an officer reasonably relies upon information indicating the existence of an outstanding warrant for a defendant. Put simply, the issue in this case is not whether the arrest was lawful or unlawful. Nor whether the warrant was valid or invalid. Rather, the highly fact-specific scenario underlying the matter before us concerns [J-62-2025] [MO: Donohue, J.] – 3 only active bench warrants and the proof required to be presented at trial for a resisting arrest conviction. In all, I find Officer Moore’s actions in this case proper and indeed compulsory, as he was informed of two bench warrants in Steadly’s name during a traffic stop. To the extent the Commonwealth did not meet its burden at trial, that is a discrete well-settled evidentiary issue.
The decision applies Pennsylvania law to the issues preserved in this appeal and explains the governing standard in the court’s own terms. The disposition controls the parties’ next steps and supplies guidance for litigants confronting the same procedural or substantive question.
Key Takeaways
- conclusion that Biagini’s behavior, including a vulgar-filled tirade, did not amount to disorderly conduct or public drunkenness and thus, “Biagini had committed no action which justified his immediate apprehension”); Commonwealth v.
- Hock, 728 A.2d 943, 947 (Pa. 1999) (holding that “Hock's remark did not constitute disorderly conduct, and the officer thus lacked probable cause to arrest her for that offense”).
- This, however, is not what occurred here.
Why It Matters
Court issues a substantive appellate ruling Pennsylvania practitioners should read the ruling with particular attention to the court’s treatment of preservation, the applicable standard, and the remedy. Those points will shape how comparable claims are framed in trial courts and reviewed on appeal.