Commonwealth v. Maldonado, 14 A.3d 907

On Nov. 9, 2008, Officer Buckman stopped an Oldsmobile for expired registration; Maldonado was the sole occupant.
Maldonado did not have a valid license or proof of insurance; the car was registered to Jacqueline Vasquez; Maldonado had three scofflaw warrants.
Officer Buckman impounded the car and began an inventory search; in the trunk he found a satchel with bags of white powder and a spoon, then a firearm, ammo, scale, and baggies after opening the satchel.
Maldonado was arrested and charged with multiple drug- and firearms-related offenses; he moved to suppress the drugs and firearm.
The trial court granted the suppression motion; the Commonwealth appealed contending Maldonado lacked standing/privacy in the car and that the inventory search was reasonable.
The Superior Court reversed, holding Maldonado failed to show a reasonable expectation of privacy in the vehicle and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Maldonado have a reasonable expectation of privacy in the vehicle?	Maldonado asserted standing and privacy in the car.	Commonwealth argued Maldonado lacked privacy in Vasquez's vehicle.	Maldonado had no reasonable expectation of privacy; standing failed.
Was the inventory search reasonable under the totality of the circumstances and thus warrant suppression?	Inventory search was reasonable and did not require suppression.	Search was improper clinical suppression warranted.	Not reached on appeal; remanded after ruling on privacy standing.

Commonwealth v. Burton, 973 A.2d 428 (Pa.Super.2009) (standing requires privacy in the searched area; vehicle searches demand privacy interest)
Commonwealth v. Foglia, 979 A.2d 357 (Pa.Super.2009) (standard of review for suppression determinations)
Commonwealth v. Peterson, 535 Pa. 492, 636 A.2d 615 (1993) (automatic standing for possessory offenses but must prove privacy in searched area)