Commonwealth v. Garvin
50 A.3d 694
| Pa. Super. Ct. | 2012Background
- Appellant was arrested on September 8, 2010 for prostitution, promoting prostitution, reckless endangerment, and criminal solicitation in Philadelphia County.
- At a suppression hearing, the court allowed some statements but suppressed follow-up questions not listed on the medical form; routine medical checklist responses remained admissible.
- Appellant was found guilty of prostitution (as a graded offense based on HIV status) and criminal solicitation, with solicitation merged for sentencing.
- Appellant received a six to twelve month prison term and two years of reporting probation; immediate parole was granted.
- Appellant appealed, arguing the statements were improperly obtained without Miranda warnings during custodial questioning that sought incriminating information in biographical questions.
- The Superior Court affirmed, holding the “routine booking exception” applied and the statements were not suppressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Appellant’s statements were improperly obtained without Miranda warnings. | Garvin contends the biographical questions elicited incriminating responses. | Commonwealth argues routine, non-interrogative booking questions do not require Miranda warnings. | suppression denied; routine booking, not custodial interrogation, warnings not required. |
Key Cases Cited
- Commonwealth v. Mistier, 590 Pa. 390, 912 A.2d 1265 (Pa. 2006) (review of suppression rulings; factual findings binding; de novo legal review)
- Commonwealth v. Pruitt, 597 Pa. 307, 951 A.2d 307 (Pa. 2008) (standard for reviewing suppression rulings; evidence viewed in context)
- Commonwealth v. Snyder, 599 Pa. 656, 963 A.2d 396 (Pa. 2009) (de novo review of legal conclusions from findings)
- Commonwealth v. Briggs, 608 Pa. 430, 12 A.3d 291 (Pa. 2011) (recent suppression standard; binding on review)
- Commonwealth v. Jasper, 526 Pa. 497, 587 A.2d 705 (Pa. 1991) (limits on Miranda warnings for biographical questions; routine form responses not suppressed)
- Commonwealth v. Yarris, 519 Pa. 571, 549 A.2d 513 (Pa. 1988) (Miranda warnings triggered by custodial interrogation, not routine questions)