Com. v. Anderson, W., 372 MDA 2015

Appeal concerns entry into a private home to execute an arrest warrant and whether "reasonable belief" that the arrestee lives in and is present at the premises permits warrantless entry.
Majority relied on Commonwealth v. Romero for the proposition that authorities with a reasonable belief an arrestee lives in given premises may enter without a search warrant.
Concurring judge (Ott, J.) argues "reasonable belief" should be defined as probable cause, following Third Circuit guidance in United States v. Vasquez-Algarin and other federal precedents.
Concurring opinion emphasizes the heightened privacy protections afforded to the home under the Fourth Amendment (Payton, Steagald, Jardines, Silverman).
In the specific facts, officers had information (warrant packet and on-scene observations, including a bicycle matching the arrestee's mode of transport) supporting probable cause that Ramos lived at and was present at 2308 Orange Street when they attempted to execute the arrest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "reasonable belief" to enter a home to execute an arrest warrant requires probable cause	Reasonable belief (as cited in Romero) permits entry without a search warrant	"Reasonable belief" must mean probable cause given the home's high Fourth Amendment protection	Concurring judge adopts the view that "reasonable belief" in this context embodies the probable cause standard; facts here met that standard
Whether officers had sufficient basis to force entry into the residence	Officers relied on warrant packet and corroborating on-scene facts (bicycle) to justify entry	Defense likely argued absence of judicially determined probable cause to search the home	Court (concurring view) found the officers possessed probable cause to believe the arrestee lived at and was present in the residence

Payton v. New York, 445 U.S. 573 (establishes limits on warrantless home entries to effectuate arrests)
Steagald v. United States, 451 U.S. 204 (protects home occupants from warrantless entry to search for third parties)
Florida v. Jardines, 133 S. Ct. 1409 (home as core Fourth Amendment space; limits on investigatory use of the home’s curtilage)
Silverman v. United States, 365 U.S. 505 (articulates the sanctity of the home against unreasonable governmental intrusion)
United States v. Martinez-Fuerte, 428 U.S. 543 (discusses levels of Fourth Amendment protection for private homes)
United States v. Gorman, 314 F.3d 1105 (Ninth Circuit: "reasonable belief" in Payton context embodies probable cause)
United States v. Barrera, 464 F.3d 496 (Fifth Circuit endorsing probable-cause-level standard for reasonable belief in home-entry context)