Commonwealth v. Williams, 165 A.3d 994

Commonwealth appeals from suppression order granting pre-trial suppression motion by Williams.
Williams faced multiple PWID counts, a paraphernalia count, and related charges.
suppression hearing Oct. 6, 2016 featured Erie Police testimony about a March 18, 2016 shooting at 1016 West 4th Street.
Police linked Williams to the Knights Inn; key card and room discrepancies suggested possible information about a room where a victim or suspect might be.
Officers entered Knights Inn room 231 without a warrant; contraband was observed and later seized under a warrant, prompting suppression.
Trial court ruled Williams had a legitimate privacy interest in room 231, suppressing the evidence; Commonwealth appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams had a legitimate expectation of privacy in room 231.	Commonwealth: no valid privacy interest; room 231 not shown to be Williams's occupancy.	Williams: maintained privacy in the room as a hotel guest/occupant under applicable standards.	Commonwealth prevailed; Williams failed to prove a legitimate expectation of privacy in room 231.

Commonwealth v. Brundidge, 620 A.2d 1115 (Pa. 1993) (hotel room Fourth Amendment protections to occupants)
Commonwealth v. Dean, 940 A.2d 514 (Pa. Super. 2008) (hotel guest privacy expectations during valid rental period)
Commonwealth v. Enimpah, 106 A.3d 695 (Pa. 2014) (no privacy interest means no need to address warrant exceptions)
Commonwealth v. Millner, 585 Pa. 237 (2005) (subjective and objective privacy expectations; protecting secrecy alone is not enough)
Commonwealth v. Viall, 890 A.2d 419 (Pa. Super. 2005) (totality of circumstances in determining reasonableness of privacy expectation)
Commonwealth v. Korn, 139 A.3d 249 (Pa. Super. 2016) (privacy expectation must be legitimate and reasonable)
Commonwealth v. Brown, 996 A.2d 473 (Pa. 2010) (standard for reviewing suppression orders; de novo on law)