PA Supreme Court: Commonwealth Must Prove the Warrant Was Valid to Convict a Defendant of Resisting Arrest Where the Warrant Was the Only Basis for the Arrest

Zak T. Goldstein, Esquire - Philadelphia Criminal Defense Lawyer

The Pennsylvania Supreme Court has decided Commonwealth v. Steadly, 62 EAP 2024 (Pa. July 21, 2026), holding that when police arrest a defendant based solely on a warrant, the Commonwealth must produce evidence at trial that the warrant was actually valid in order to prove the lawful arrest element of resisting arrest. Testimony that a warrant appeared in a police database and that a dispatcher confirmed it over the radio is not enough. Because the Commonwealth never produced the warrants or any evidence of their validity, the Supreme Court reversed the defendant’s conviction and vacated his sentence.

What Happened in Commonwealth v. Steadly?

On an evening in August 2021, a Philadelphia police officer stopped the defendant for driving with an illegally tinted windshield. The defendant could not produce his license, registration, or proof of insurance, but he identified himself verbally. The officer returned to his cruiser, ran that information through the Mobile Data Terminal in his patrol car, and saw two bench warrants in the defendant’s name. A police dispatcher then confirmed over the radio that the warrants were active. Bench warrants typically issue when a person fails to appear in court. The officer admitted at trial that he had no idea what the warrants were for and that the warrants were the only reason he decided to arrest the defendant.

When the officer ordered the defendant to turn off the car and get out, the defendant refused. The officer opened the door and tried to remove him, and a struggle followed. The defendant dislodged the officer’s body camera and elbowed him in the face, although the officer testified that he was not hurt. Several officers needed one to two minutes to subdue him. The Commonwealth charged the defendant with recklessly endangering another person (“REAP”) and resisting arrest under 18 Pa.C.S. § 5104.

At a bench trial in Philadelphia Municipal Court, the trial judge sustained a best evidence objection to the officer’s testimony about what the database said, allowing that testimony only to explain why the officer decided to make the arrest. The Commonwealth never introduced the warrants themselves, any records from the database, or any other evidence that the warrants were valid. The court acquitted Steadly of REAP but convicted him of resisting arrest and sentenced him to six months of probation. The Court of Common Pleas denied his petition for writ of certiorari, and the Superior Court affirmed. In the Superior Court’s view, the officer had probable cause to believe that warrants existed, and that belief alone made the arrest lawful for purposes of the resisting arrest statute.

The Supreme Court’s Ruling

The Supreme Court reversed in a majority opinion by Justice Donohue. Resisting arrest is unusual among criminal statutes because the legislature made a lawful arrest an element of the offense. A defendant cannot be convicted of resisting arrest unless the underlying arrest was lawful. Commonwealth v. Biagini, 655 A.2d 492, 497 (Pa. 1995). The Commonwealth therefore must prove the lawfulness of the arrest beyond a reasonable doubt at trial, just like every other element of a criminal offense.

An arrest based solely on a warrant is lawful only if the warrant is valid. Under the collective knowledge doctrine, an officer in the field may rely on a database entry, a bulletin, or a radio call in deciding to make an arrest. Whiteley v. Warden, 401 U.S. 560 (1971). But that reliance does not insulate the arrest from review in court. If the underlying warrant turns out to be invalid, the arrest was unlawful no matter how reasonably the officer acted. The Court held that when an arrest is justified solely on the basis of a warrant, “the Commonwealth must produce evidence of the validity of the warrant beyond an officer’s second-hand knowledge of its existence to prove the arrest was lawful.” It explained that “[p]roof that a warrant exists, by virtue of its appearance in a police database, is never sufficient evidence of its validity under any standard of proof.” A database entry may reflect a warrant that already expired, was previously served, or was issued without probable cause in the first place.

The Court rejected the Superior Court’s line of cases holding that an officer’s probable cause to believe a warrant exists is enough, and it expressly disapproved Commonwealth v. Heidelberg, 267 A.3d 492 (Pa. Super. 2021) (en banc), on that point. Under the Superior Court’s approach, an arrest could qualify as lawful even if no warrant existed at all, so long as the officer reasonably believed one did. The Supreme Court called that standard constitutionally untenable. It observed that the approach effectively imported the federal good faith exception into Pennsylvania law, even though the Court rejected that exception under Article I, Section 8 of the Pennsylvania Constitution in Commonwealth v. Edmunds, 586 A.2d 887 (Pa. 1991). Because the Commonwealth produced no evidence of the warrants’ validity, the evidence was insufficient as a matter of law, and the Court reversed the conviction outright. Justice Mundy dissented.

The Takeaway

Steadly matters because warrant arrests happen every day, and police databases are not always right. Warrants can linger in the system long after they have been served, recalled, or satisfied. Going forward, when the Commonwealth prosecutes someone for resisting arrest and the only basis for the arrest was a warrant, it must come forward with real evidence that the warrant was valid. Testimony that an officer saw the warrant in a database or heard about it from a dispatcher will not sustain a conviction. The Court did not spell out exactly what proof will suffice in future cases. It held only that the Commonwealth must present some evidence of the warrant’s validity so that the court or jury can decide whether the arrest was lawful. Defense attorneys should hold the Commonwealth to that burden and challenge the sufficiency of the evidence when the proof falls short.

One caution: Steadly does not give anyone a license to fight the police. The Court repeated the rule that a dispute about the lawfulness of an arrest “is an issue to be resolved in a courtroom, not on a street corner.” Biagini, 655 A.2d at 497. A person who commits new crimes while resisting, such as assaulting an officer, may still be prosecuted for those crimes even if the arrest itself was unlawful. The better course is always to comply and then fight the case in court, where decisions like Steadly give the defense real tools to win.

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