Commonwealth v. Johnson, 33 A.3d 122

Detective Dacus, with a confidential informant (CI), learned three black males were selling crack at 457 E. 8th St, Apt. 1; CI had made multiple buys yielding cocaine.
Surveillance over 24 hours showed 20+ people entering/exiting the apartment quickly; owner confirmed new tenants; lease listed Mahlon Ross, Earl Ross, and Ron Ross, claiming relocation from Michigan.
Based on CI information and controlled buys, police sought a search warrant for 457 E. 8th St, Apt. 1 and the three occupants; Johnson was charged along with two other residents after the search yielded narcotics.
Johnson moved to suppress the evidence, arguing the warrant was defective; the suppression court denied the motion; trial proceeded with two days of testimony.
Johnson was convicted of possession of a controlled substance, PWID, possession of drug paraphernalia, and conspiracy; he was sentenced to 84–168 months’ imprisonment with 78 months’ probation; he appealed pro se after Grazier proceedings allowed self-representation.
The Superior Court affirmed, addressing only the suppression warrant particularity and the production of the CI for defense, and noting issues around preservation/waiver of discovery requests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant’s lack of particularity as to the persons to be searched invalidates it.	Johnson argues the warrant failed to describe the three targets with sufficient particularity.	Commonwealth contends the warrant’s description, including physical traits, was sufficiently precise.	No error; descriptions were sufficiently precise to identify the intended persons.
Whether Johnson was entitled to production of the CI at suppression to refute the affidavit.	Johnson sought CI production to challenge probable cause.	Commonwealth argues discovery decisions are discretionary and the issue was waived.	Waived; even if preserved, relief would be denied.

Commonwealth v. Leonard, 951 A.2d 393 (Pa. Super. 2008) (standard for reviewing suppression rulings; factual findings reviewed for support and legal conclusions de novo)
Commonwealth v. Belenky, 777 A.2d 483 (Pa. Super. 2001) (greater protection under PA Constitution; strictness of particularity depends on context)
Commonwealth v. Rega, 593 Pa. 659 (Pa. 2007) (read warrants in common-sense fashion; avoid hypertechnical invalidation; place must be described with reasonable specificity)
In re Search Warrant B-21778, 341 Pa. Super. 350 (Pa. Super. 1985) (illustrates particularity standard for warrants describing items to be searched)
Commonwealth v. Hawkins, 880 A.2d 678 (Pa. Super. 2005) (distinguishes warrants for 'all persons present' from targeted searches)
Commonwealth v. Baker, 946 A.2d 691 (Pa. Super. 2008) (informant-production discovery standard; Bonasorte framework)
Commonwealth v. Grazier, 552 Pa. 9 (Pa. 1998) (permits self-representation after a Grazi er hearing)