Com. v. Jones, R., III
463 MDA 2021
| Pa. Super. Ct. | Apr 12, 2022Background
- On Feb. 26, 2020, state troopers stopped a gray Nissan Sentra on I-78 (a known drug corridor) for missing PA inspection/emission stickers; the Sentra was a rental from Avis.
- Driver Richard L. Jones III and passenger Trai’vone Ferguson were not named on the rental agreement; troopers noted signs they associated with trafficking (energy drink, ash, multiple air fresheners, inconsistent travel stories, nervousness).
- Ferguson admitted there was a marijuana joint in the center console; Trooper Dreisbach then asserted probable cause and searched the car, opening the trunk and finding a backpack with a vacuum-sealed kilogram that tested positive for cocaine.
- Troopers claimed they would have towed the vehicle because occupants were not on the rental agreement; they did not contact the rental company or the named renter.
- Suppression court: traffic stop extension and joint admission were lawful, but the trunk search was a warrantless search invalid under Commonwealth v. Alexander because no exigent circumstances were shown; consequently suppressed trunk drugs, cell-phone data, and post-search statements as fruits of the poisonous tree.
- Commonwealth appealed, arguing the search evidence was admissible under inevitable discovery (via a lawful tow under the Vehicle Code) and urged adoption of a good-faith exception; Superior Court affirmed the suppression order.
Issues
| Issue | Commonwealth's Argument | Jones's Argument | Held |
|---|---|---|---|
| 1) Whether probable cause alone justified a warrantless vehicle search | Probable cause supported search; Alexander notwithstanding, search lawful | Alexander requires both probable cause and exigent circumstances; no exigency here | Court: Alexander controls — probable cause alone insufficient; search unlawful |
| 2) Whether suppressed evidence was admissible under inevitable discovery / good-faith exception | Evidence would have been inevitably discovered via an inventory after towing (Vehicle Code authority); alternatively, adopt a good-faith exception | Towing was not legally justified based on the record; no good-faith exception under PA Constitution | Court: Inevitable discovery failed (no statutory basis shown for tow); PA law rejects a good-faith exception — suppression affirmed |
Key Cases Cited
- Commonwealth v. Alexander, 243 A.3d 177 (Pa. 2020) (Pennsylvania requires probable cause plus exigent circumstances to justify warrantless automobile searches)
- Commonwealth v. Edmunds, 586 A.2d 887 (Pa. 1991) (Pennsylvania does not recognize a good-faith exception to the exclusionary rule)
- Commonwealth v. King, 259 A.3d 511 (Pa. Super. 2021) (explaining application of the inevitable discovery doctrine)
- Commonwealth v. Bailey, 986 A.2d 860 (Pa. Super. 2009) (defining the inevitable discovery doctrine standard)
- Commonwealth v. Heidelberg, 267 A.3d 492 (Pa. Super. 2021) (Commonwealth burden at suppression hearing)
- Commonwealth v. Korn, 139 A.3d 249 (Pa. Super. 2016) (standard of review for suppression rulings)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warning principle cited)