Commonwealth v. Goldsborough
31 A.3d 299
| Pa. Super. Ct. | 2011Background
- Appellant Commonwealth appeals a suppression order suppressing evidence from Goldsborough's arrest for drug offenses.
- CI-1 informed Trooper Skahill in Jan 2009 that Goldsborough trafficked cocaine and hid cocaine in a gray Nissan 350Z and gold Mercedes; CI-1 had prior reliable cooperation with police.
- CI-2 informed Officer Tyler that Goldsborough supplied cocaine throughout Chester and that Goldsborough used Nissan and Mercedes to traffic; CI-2 had ten years of reliable cooperation.
- Surveillance on Feb 5, 2009 documented Goldsborough's movements: Mercedes near 323 Rural Ave, then Nissan observed across street; later burglary report prompted police contact.
- Goldsborough was detained after exiting the Nissan; officers recovered a scale with cocaine residue, marijuana, and vehicle keys; cash and drugs were later seized under warrants.
- Suppression court held no reasonable suspicion or probable cause for seizure/arrest; suppression order was entered, later reconsidered and reinstated after an evidentiary petition; Commonwealth appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause/suspicion based on informants | Goldsborough lacked reasonable suspicion or probable cause. | Commonwealth argues two independent, reliable informants plus corroboration established probable cause for detention/arrest. | Commonwealth wins: probable cause established; suppression reversed. |
| Warrant applications' sufficiency without post-arrest information | Evidence from arrest supports warrants; suppressing warrants as fruit of arrest is improper. | If arrest info tainted evidence, warrants may still be supported by independent probable cause. | Not addressed due to resolution of issue 1. |
Key Cases Cited
- Commonwealth v. Lehman, 857 A.2d 686 (Pa.Super.2004) (scope of appellate review of suppression findings; credibility-bound)
- Commonwealth v. Keller, 823 A.2d 1004 (Pa.Super.2003) (law applied to suppression and evidentiary rulings)
- Commonwealth v. Nester, 551 Pa. 157 (Pa.1998) (probative value of suppression-related determinations)
- Commonwealth v. Luv, 557 Pa. 570 (Pa.1999) (informant reliability and corroboration for probable cause)
- Commonwealth v. Dukeman, 917 A.2d 338 (Pa.Super.2007) (two independent informants bolster reliability to establish probable cause)
- Commonwealth v. Williams, 2 A.3d 611 (Pa.Super.2010) (probable cause and totality of the circumstances; informant corroboration)
- Commonwealth v. Teeter, 961 A.2d 890 (Pa.Super.2008) (factors for distinguishing investigative detention from arrest)