Com. v. Martin, T.
Com. v. Martin, T. No. 1855 WDA 2015
| Pa. Super. Ct. | Mar 31, 2017Background
- Police received CI information that "Ryder" (identified as Chauncey Howard) and "Troy" (identified as Troy Martin) were storing and distributing heroin from 714 Mercer Street and used a rented black Chrysler van for deliveries.
- Officers corroborated CI details: photo identifications of Howard and Troy, property records showing Albert Martin as owner, a prior arrest record linking Troy to 714 Mercer Street, and surveillance observing Troy enter and exit the van and residence.
- Officers performed a trash pull from curbside bags outside 714 Mercer Street and, at the station, found manipulated sandwich bag corners, small amounts of marijuana (field-test positive), and indicia/prescription bottles for Albert Martin; officers testified these items are consistent with narcotics packaging and distribution.
- Based on the affidavit incorporating the CI and investigative corroboration (including trash pull results), a magistrate issued a warrant; the subsequent search recovered large quantities of heroin, cocaine, drug paraphernalia, cash, firearms, and an iPhone; Troy Martin made incriminating statements after Miranda warnings.
- The trial court granted Martin’s suppression motion, finding the affidavit insufficient to establish probable cause (particularly criticizing lack of CI reliability detail and that the trash results did not show "large amounts of heroin").
- The Commonwealth appealed; the Superior Court reviewed whether the affidavit provided a substantial basis for the magistrate’s probable cause determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the affidavit sufficient to support issuance of the search warrant? | Commonwealth: CI details plus substantial police corroboration (IDs, surveillance, trash pull) created a fair probability contraband/evidence would be found. | Martin: Affidavit lacked information on CI reliability and failed to corroborate that large amounts of heroin were stored at the residence. | The Superior Court reversed the suppression order: magistrate had substantial evidence and the warrant was supported by probable cause under a totality-of-the-circumstances standard. |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (1983) (establishes the practical, totality-of-the-circumstances test for probable cause based on hearsay and CI information)
- United States v. Leon, 468 U.S. 897 (1984) (deference to magistrate and good-faith doctrine; differing magistrates may reach different conclusions)
- Commonwealth v. Gagliardi, 128 A.3d 790 (Pa. Super. 2015) (reviewing court must defer to magistrate and use common-sense evaluation of affidavit)
- Commonwealth v. Davis, 595 A.2d 1216 (Pa. Super. 1991) (affidavit need not establish certainty that evidence will be found)
- Commonwealth v. Forster, 385 A.2d 416 (Pa. Super. 1978) (similar principle that absolute certainty is not required)
- Commonwealth v. Carter, 105 A.3d 765 (Pa. Super. 2014) (standard of review for suppression: accept factual findings supported by record, review legal conclusions de novo)