The Pennsylvania Superior Court affirmed a defendant’s conviction and held that the commonwealth was not required to prove exigent circumstances when an officer had lawfully seized a firearm in a vehicle under the plain view doctrine.

On Jan. 16, 2020, Markee Davis was observed by Philadelphia police officers driving a dark blue Acura with dark-tinted windows on 22nd Street. Officers Daniel Levitt and Paul Narrigan saw the Acura traveling southbound at a very high rate of speed, passing cars, and driving on the shoulder. Davis made a hard right onto Allegheny Avenue without using his turn signal. The officers activated their lights and sirens and pulled him over. Davis pulled over in an illegal parking spot, according to the opinion.

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