Com. v. Hill, S., Com. v. Hill, S. No. 1080 MDA 2016

The appeal concerns suppression of evidence based on an affidavit for a search warrant targeting Syeen Hill's residence in Lancaster County.
Detective Weber initiated the investigation after obtaining Hill's address from the Lancaster County Probation Office, not from a confidential informant tip.
The affidavit described a single controlled purchase and Hill's conduct with unknown individuals near his residence, but lacked detail about where, when, and duration of the transactions.
The majority found nexus between Hill's cocaine business and his residence, relying on phrases that the activity was consistent with contraband and that drug dealers keep contraband at home.
The dissent argues those phrases do not establish a nexus absent corroborating facts, and notes the affidavit did not show Hill kept drugs at his residence or that informants corroborated such a claim.
The dissent compares the case to Commonwealth v. Kline and Commonwealth v. Gagliardi, contending the affidavit here is insufficient to show probable cause for a residence-based search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the affidavit establish nexus between Hill's drug business and his residence?	Hill's business nexus is not shown by a single transaction and generic statements.	Observations of conduct near the residence plus informant corroboration support nexus.	No; nexus not sufficiently established.
Is probable cause to search Hill's residence established without corroborating informant details?	Lack of where/when/how long details undermine probable cause.	Corroborating informants and observed activity suffice for probable cause.	No; probable cause lacking.

Commonwealth v. Kline, 335 A.2d 361 (Pa. Super. 1975) (insufficient where transaction details lack location and timing)
Commonwealth v. Gagliardi, 128 A.3d 790 (Pa. Super. 2015) (presence of multiple transactions not binding without residence nexus)
Commonwealth v. Davis, 595 A.2d 1216 (Pa. Super. 1991) (informant tip linked to defendant's address and transactions near residence)
Commonwealth v. Clark, 595 A.2d 1216 (Pa. Super. 2011) (informant identified residence as place of cocaine packaging and distribution)
Commonwealth v. Randolph, 151 A.3d 170 (Pa. Super. 2016) (officer experience may be considered but cannot substitute specific facts)