concurring.
I concur with the Majority to the extent that it rejects Appellant’s contentions that this Court must give precedential value to the per curiam orders rendered by this Court in the wake of Commonwealth v. Banks, 540 Pa. 453, 658 A.2d 752 (1995). Moreover, while I recognize the principles of stare decisis, especially considering the analogous factual circumstances between the instant appeal and Commonwealth v. Dunlap, 596 Pa. 147, 941 A.2d 671 (2007), cert. denied, ___ U.S. ___, 129 S.Ct. 448, 172 L.Ed.2d 321 (2008), I am constrained to agree with the Majority concerning the confusing nature of the “lens” theory as portended by Mr. Justice Saylor’s concurring opinion in Dunlap, and the dissenting statement issued by Chief Justice John G. Roberts, Jr., in the United States Supreme Court’s denial of certiorari in Dunlap1 Indeed, I completely agree with the Majority that an officer’s experience should be a relevant factor in determining *223probable cause, with the extremely important caveat that “a court cannot simply conclude that probable cause existed based upon nothing more than the number of years an officer has spent on the force. Rather, the officer must demonstrate a nexus between his experience and the search, arrest, or seizure of evidence.” Majority Op. at 210, 985 A.2d at 935 (quoting Dunlap, 941 A.2d at 676.). In so much as it draws a distinction between the “lens” theory and this clarification, I join the Majority.
My agreement with the Majority must end here, however, because I cannot concur that the “high-crime” nature of the neighborhood “is a relevant factor.” Majority Op. at 212 n. 11, 985 A.2d at 937 n. 11. Indeed, while the Majority explicitly adopts the portions of Justice Saylor’s concurring opinion in Dunlap concerning the relevance of an officer’s experience, in the same breath, it explicitly rejects his salient observations that “in the absence of some particular circumstance that does not substantially overlap with legitimate behavior ... the high-drug activity location factor should [not] be given the sort of weight which would tip the totality scales in favor of finding probable cause----” Majority Op. at 212 n. 11, 985 A.2d at 937 n. 11 (quoting Dunlap, 941 A.2d at 681 (Saylor, J., concurring)). Like Justice Saylor herein, “I am unable meaningfully to distinguish the circumstances in this appeal from those underlying our recent decision in [Dunlap],” Dissenting Op. at 226, 985 A.2d at 945 (Saylor, J.), as I can discern no “particular circumstance that does not substantially overlap with legitimate behavior.” Dunlap, 941 A.2d at 681 (Saylor, J., concurring).
Rather, in my view, it appears that the Majority clearly has given the high-crime nature of the neighborhood at issue here “the sort of weight which would tip the totality scales in favor of finding probable cause,” Dunlap, 941 A.2d at 681 (Saylor, J., concurring), as that is the only way to distinguish the facts of this case from those presented in Dunlap. While I recognize that the police officers in this case may have ultimately “got it right,” in that they arrested a man with drugs on his person, the long-term, overarching effect of this decision, *224resulting in an “ends justify the means” circumstance, is far more troubling.
The unfortunate result of today’s decision is that the low socio-economic character of a neighborhood will now be enough to suffice the rigorous standards of probable cause for any citizen, not just the street-level heroin dealer. While I understand that, in the social norms of today’s world, drug transactions may occur more often in neighborhoods such as the one here, the rights of Pennsylvania residents in both high-crime and low-crime areas remain the same under our Constitution. To be sure, if police can now use evidence of the high-crime nature of the neighborhood to demonstrate probable cause, then the simple action of shaking a friend’s hand upon greeting will subject those Mends potentially to being searched and seized, while the same occurrence in a low-crime area will not. Such a conclusion is patently offensive to our longstanding constitutional principles protecting every person in our society from intrusive action by the state, even in the face of an ever-increasing drug problem on our streets. See e.g. Illinois v. Wardlow, 528 U.S. 119, 120 S.Ct. 673, 145 L.Ed.2d 570 (2000) (“An individual’s presence in an area of expected criminal activity, standing alone, is not enough to support a reasonable, particularized suspicion that the person is committing a crime.”); Whren v. United States, 517 U.S. 806, 813, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996) (recognizing that the Constitution prohibits selective enforcement of the law based upon subjective considerations.).
I fully realize that a drug transfer in this case could have occurred, and that probable cause does not require absolute certainty. See Los Angeles County, California v. Rettele, 550 U.S. 609, 615, 127 S.Ct. 1989, 167 L.Ed.2d 974 (2007). Nevertheless, the regrettable outcome of this decision places the deciding factor in a case, not on the perceived action, but rather on the location of that action. Again, while an arresting officer may be proved correct in his hunch, such is not an accepted constitutional norm.
Finally, the observations made by Madame Justice Todd and Mr. Justice Saylor in their dissenting opinions instantly, *225as well as the ones I have now delineated, do not prohibit police from removing drug dealers from the streets. As recognized by the decisions in Commonwealth v. Lawson, 454 Pa. 23, 309 A.2d 391 (1973), Banks, and Dunlap, multiple transactions are surely to occur if the defendant is indeed a drug dealer. For this reason, I would support a finding of probable cause in a case where an officer witnesses multiple suspected drug transactions, because probable cause would be based upon repeated conduct and action, and not merely a location. Nevertheless, this Court, as the “last line of defense” for the protection of the constitutional interests of the citizens of this Commonwealth, should not remove reasonable constitutional constraints and, therefore, subject the entire population of a disadvantaged neighborhood to infringement of their Fourth Amendment rights.
Accordingly, because I agree with Justice Saylor’s salient conclusion in Dunlap that we must not use the socio-economic character of a neighborhood as the tipping point in favor of finding probable cause, I must respectfully dissent to that aspect of the opinion.
. In so doing, I recognize that I joined the Majority in Dunlap, and further did not join Justice Saylor’s concurring opinion. After long and careful consideration, however, I am now fully cognizant of the difficulties of police officers and trial judges alike in applying the "lens” theory espoused by the Dunlap majority.