Commonwealth v. Romero, 138 A.3d 21

Police had an arrest warrant for fugitive Earnest Moreno (absconded from a DRC halfway house while on parole); the warrant listed 4745 N. 2nd St. (Appellees’ address) as Moreno’s likely residence.
Parole Agent Sean Finnegan and U.S. Marshals went to 4745 N. 2nd St., knocked, announced, and were admitted by an occupant; Finnegan said he was looking for Moreno and then searched the house despite Appellees’ objections.
During the search of the basement, officers discovered 61 marijuana plants; Narcotics Strike Force obtained a search warrant and seized additional drug paraphernalia and a handgun; Romero and Castro were charged.
Appellees moved to suppress, arguing the initial entry/search incident to the Moreno arrest warrant was unlawful (stale information and no showing Moreno resided there), and other related suppression grounds; the trial court suppressed the evidence.
The Superior Court reviewed the suppression hearing record (finding Finnegan credible and adopting his factual testimony that Moreno had listed Appellees’ address on multiple government records) and reversed, holding the officers reasonably believed Moreno’s last known address was 4745 N. 2nd St., so entry incident to the arrest warrant was lawful.

Issue	Commonwealth's Argument	Appellees' Argument	Held
Whether officers with an arrest warrant for a fugitive may enter/search third‑party residence listed as fugitive’s likely address	Entry was lawful because officers had reasonable grounds to believe the fugitive resided at 4745 N. 2nd St.	Entry was unlawful because the address evidence was stale, lacked recent corroboration, and did not show Moreno actually resided there	Reversed suppression: officers reasonably believed the address was Moreno’s last residence; entry was lawful
Whether evidence discovered during the entry must be suppressed as fruit of an illegal search	Suppress not required if initial entry was valid; facts supported validity	Evidence should be suppressed because initial entry/search was illegal	Held suppression improper because initial entry was valid

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda requirements for custodial interrogation)
Staegald v. United States, 451 U.S. 204 (U.S. 1981) (arrest warrant for fugitive does not authorize entry into third‑party residence unless fugitive is believed to reside there)
Maryland v. Garrison, 480 U.S. 79 (U.S. 1987) (validity of warrant assessed on information disclosed to magistrate)
Commonwealth v. Muniz, 5 A.3d 345 (Pa. Super. 2010) (officers may enter when they reasonably believe fugitive resides at address; testimonial corroboration supports reasonableness)
Commonwealth v. Conception, 657 A.2d 1298 (Pa. Super. 1995) (arrest warrant listing address as fugitive’s residence can justify entry into third‑party dwelling)
Commonwealth v. Brown, 996 A.2d 473 (Pa. 2010) (appellate review: factual findings of suppression court binding; legal conclusions reviewed de novo)
Commonwealth v. Bonasorte, 486 A.2d 1361 (Pa. Super. 1984) (Commonwealth’s burden at suppression hearing is by preponderance of the evidence)