211 A.3d 1253
Pa. Super. Ct.2019Background
- On Dec. 17, 2016, police responded to a domestic call in Fannett Township; the victim (Ms. Harry) reported her boyfriend, Isaiah Baker, left the scene and had taken a handgun and ammunition. Police believed Isaiah was prohibited from possessing firearms.
- Police developed information Isaiah might be at appellants Wayne Gray Jr.’s and Nicole Baker’s Chambersburg residence. State and local officers went to that house without a search or arrest warrant.
- Officers encountered resistance at the door; despite objections that a warrant was required, officers entered the home, went upstairs, and apprehended Isaiah. Evidence from the entry led to charges against Gray and Nicole Baker for obstructing administration of law, resisting arrest, and hindering apprehension.
- Appellants moved to suppress evidence obtained during the warrantless entry. The suppression court denied the motions, concluding exigent circumstances justified the entry (factors cited: alleged weapon, presence of suspect, gravity of offense, night time, peaceable entry).
- After a joint jury trial, appellants were convicted and sentenced. They appealed, arguing the warrantless entry was unconstitutional and suppression should have been granted.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Appellants) | Held |
|---|---|---|---|
| Whether exigent circumstances justified warrantless entry into appellants’ home | Entry justified because (1) report of stolen handgun and ammunition, (2) suspect was a felon and believed armed, (3) probable cause suspect was inside, and (4) danger to police/public | No exigency: victim was no longer at scene, suspect was not fleeing, exits were under surveillance, officers could have obtained a warrant, and delay would not risk imminent harm | Reversed suppression denial; no exigent circumstances existed to justify warrantless entry |
Key Cases Cited
- Commonwealth v. Ford, 175 A.3d 985 (Pa. Super. 2017) (standard of review for suppression rulings and exigent-circumstances framework)
- Commonwealth v. Caple, 121 A.3d 511 (Pa. Super. 2015) (exigent-circumstances exception and list of balancing factors)
- Commonwealth v. Rispo, 487 A.2d 937 (Pa. Super. 1985) (exigency not shown where surveillance could continue until warrant obtained)
- Commonwealth v. Martin, 620 A.2d 1194 (Pa. Super. 1993) (arrest warrant for third party does not authorize searching a private home absent exigency)
- Commonwealth v. Wright, 742 A.2d 661 (Pa. 1999) (domestic-violence context does not automatically create exigency where risk of imminent harm has ended)
- Commonwealth v. Romero, 183 A.3d 364 (Pa. 2018) (Fourth Amendment protection of the home; warrants required to search a residence absent exigent circumstances)