Commonwealth v. Bloom

In Commonwealth v. Bloom, 2009 PA Super 150, 979 A.2d 368 (Pa. Super. 2009), the Superior Court held that a Port Authority police officer had primary jurisdiction to stop a defendant that committed a traffic violation. In Bloom, the defendant, while travelling on a state road, drove through a red light that was activated by a Port Authority-owned signaling system and located 500 feet from a Port Authority-owned and operated tunnel. A Port Authority officer patrolling the tunnel observed the defendant's violation, pulled him over on the state road approximately 75 feet from the traffic light and 150 feet from the tunnel, and subsequently arrested him for DUI. Bloom, 979 A.2d at 372. Because the traffic violation occurred within the immediate and adjacent vicinity of Port Authority property, the Superior Court concluded that the Port Authority officer had primary jurisdiction to stop and arrest the defendant. Id. In Bloom, the Superior Court determined that the Port Authority Police Officer did have primary jurisdiction to effectuate a traffic stop because the traffic violation occurred in the "immediate and adjacent vicinity" of Port Authority Property. The uncontradicted testimony of the arresting officer established that: (1) he was patrolling the Wabash Tunnel which is Port Authority property; (2) the Wabash Tunnel ramp intersects with Woodruff Street which is a municipal street; (3) the traffic light on Woodruff Street is triggered by a Port Authority-owned signaling system, located approximately 500 feet from the tunnel, which is activated by cars exiting the Wabash Tunnel; (4) Appellee was traveling on Woodruff Street and failed to stop at the red traffic light; (5) Appellee nearly collided with two vehicles that had just proceeded from the Wabash Tunnel ramp; (6) the officer pursued Appellee's vehicle and stopped him approximately 150 feet from Port Authority property, and 75 feet from the traffic light. (N.T., 7/29/08, at 5-21). Bloom, 979 A.2d at 372. The Superior Court concluded that "this evidence was sufficient to show that Appellee committed the violation and was stopped in the "immediate and adjacent vicinity" of Port Authority property." Id.