Com. v. Coughlin, P.
3492 EDA 2016
| Pa. Super. Ct. | Nov 15, 2017Background
- On Aug. 30, 2015 police responded to reports of gunfire at Appellee Padraic Coughlin’s Philadelphia residence; neighbors reported a white male named "Pat" shooting an assault rifle in his backyard.
- Officers entered the rear yard, observed multiple shell casings, and an individual matching the description exited the residence and was immediately subdued and handcuffed.
- While Coughlin was in handcuffs outside the home, Officer Sulock asked whether anyone else was inside; Coughlin gave inconsistent answers.
- Without obtaining a warrant, officers then entered and swept the first and second floors and recovered a black assault rifle on the second floor.
- The trial court suppressed the rifle and statements made after arrest, holding the warrantless entry was not justified by exigent circumstances and that Miranda warnings were required prior to custodial questioning. The Commonwealth appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers lawfully entered the home without a warrant under exigent circumstances | Exigent circumstances existed because eyewitnesses reported an assault rifle shooting, shell casings were present, and Coughlin gave inconsistent answers about others being inside | Warrantless entry was not justified: suspect was under custody, no evidence of injured persons inside or auditory/visual signs of anyone in the home, and no emergency requiring immediate entry | Suppression affirmed: Commonwealth failed to prove exigent circumstances justified warrantless entry |
| Admissibility of statements made after arrest | Statements about presence of others justified emergency entry and are admissible | Statements were made after custodial arrest without Miranda warnings and thus inadmissible | Statements suppressed: officer questioned while Coughlin was handcuffed without Miranda warnings |
Key Cases Cited
- Welsh v. Wisconsin, 466 U.S. 740 (recognizes warrantless home entries are presumptively unreasonable)
- Payton v. New York, 445 U.S. 573 (warrantless entry into a home absent probable cause and exigent circumstances is prohibited)
- Commonwealth v. Roland, 637 A.2d 269 (framework: warrantless home entry prohibited absent probable cause and exigent circumstances; lists factors to assess exigency)
- Commonwealth v. Wadell, 61 A.3d 198 (discusses exigent-circumstances burden on police and relevant factor balancing)
- Commonwealth v. Berkheimer, 57 A.3d 171 (consideration of nighttime entries in exigency analysis)