Commonwealth v. Caple
121 A.3d 511
Pa. Super. Ct.2015Background
- Appellant Frank Caple was convicted after a 3-day jury trial of multiple drug and paraphernalia offenses and simple assault stemming from events at a Montgomery County motel (2013).
- Officers entered Room 215 of the America’s Best Value Inn without a warrant during a domestic dispute investigation, seeking the potentially endangered victim.
- Two metal crack pipes were observed in plain view in Room 215, and later a warrant was obtained to search the room for additional drug-related evidence.
- A large quantity of drugs, drug paraphernalia, and related items were recovered from Room 215 and its desk, bags, and other containers, with some items linked to Caple through various exhibits.
- Caple was sentenced on June 4, 2014, including mandatory minimum terms under 18 Pa.C.S. § 7508, with an alternate sentence provision if the statutory scheme was found unconstitutional.
- Caple timely appealed, challenging suppression of Room 215 evidence and the legality of the sentence post-Alleyne (2013) guidance).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the suppression court properly denied suppression of evidence found in Room 215 | Caple argues no exigent circumstances justified entry. | Commonwealth contends exigent circumstances existed to protect a potential victim. | Exigency supported warrantless entry; suppression denied. |
| Whether the backpack search and plain-view seizure were lawful | Caple contends plain-view seizure was invalid. | Police observed crack pipes in plain view after lawful entry. | Plain-view seizure lawful; evidence admissible. |
| Whether the initial sentence under Alleyne was illegal and should be vacated | Caple challenges mandatory minimum under Alleyne and Newman/Cardwell line. | Commonwealth concedes illegality of the initial sentence. | Initial sentence vacated; remand for resentencing required. |
| Whether an alternate sentence on appeal can be imposed without remand | Caple argues remand is necessary to re-sentence. | Commonwealth urges adoption of the trial court’s alternate sentence. | Case remanded for resentencing; alternate sentence rejected. |
| Whether authorities properly considered applicable caselaw on remand procedure | Remand should start anew; no carryover of illegal sentence. | Alternate sentence could be imposed without remand. | Remand required; start afresh at resentencing. |
Key Cases Cited
- Commonwealth v. Richter, 791 A.2d 1181 (Pa. Super. 2002) (exigent circumstances in domestic-dispute contexts allow warrantless entry)
- Commonwealth v. Turner, 982 A.2d 90 (Pa. Super. 2009) (plain-view seizure requires legality of initial entry and obvious incriminating nature)
- Janda, 14 A.3d 147 (Pa. Super. 2011) (probable cause in search warrants must be evaluated under totality of circumstances)
- Commonwealth v. Brundidge, 620 A.2d 1118 (Pa. 1993) (reasonable expectation of privacy in lodging; motel/hotel guest privacy rights)
- Illinois v. Gates, 462 U.S. 213 (1983) (totality of the circumstances standard for probable cause)