In the Interest of: S.Q., a minor, In the Interest of: S.Q., a minor No. 349 EDA 2016

Police responded to a shooting; two victims were found on a basketball court and officers learned (from an uncorroborated tip) the shooter possibly entered 3239 N. 26th Street.
Officers surveilled the house ~30–35 minutes, observed a man they had seen near the scene enter the home, then saw two men exit to the rear alley and flee back into the house when they spotted uniformed officers.
Officer Berg entered the rear door after the two men re‑entered, followed quickly by uniformed officers; they detained four men, conducted a protective sweep, and found co‑defendant Carter upstairs.
During the sweep an officer saw the partial barrel of a handgun in a closet, then later a warrant was obtained and executed; a Ruger .380 was recovered from that closet.
Defendant (a resident/minor) made inculpatory statements after being interviewed; charges included possession of firearm by a minor, conspiracy, and tampering with evidence.
The suppression court suppressed the gun and statements for this defendant, finding no probable cause or exigent circumstances for the warrantless entry; the Commonwealth appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether police lawfully entered 3239 N. 26th Street without a warrant	Warrantless entry was justified by exigent circumstances: recent shooting, suspects potentially armed, flight into house, and need to prevent destruction of evidence	Entry lacked probable cause and exigency; officers had only an uncorroborated tip and equivocal observations, so entry/search/arrest were unlawful	Suppression affirmed: no probable cause shown for entry; court did not reach exigency because lack of probable cause dispositive

Commonwealth v. Walls, 53 A.3d 889 (Pa. Super. 2012) (standard for reviewing suppression decisions)
Commonwealth v. Peterson, 17 A.3d 935 (Pa. Super. 2011) (deference to suppression court findings of fact)
In the Interest of L.J., 79 A.3d 1073 (Pa. 2013) (scope of appellate review limited to suppression hearing record)
Commonwealth v. Rushing, 71 A.3d 939 (Pa. Super. 2013) (warrantless searches of residences require probable cause plus exigent circumstances)
Commonwealth v. Wright, 961 A.2d 119 (Pa. 2008) (same principle on warrantless residential entries)
Commonwealth v. Griffin, 24 A.3d 1037 (Pa. Super. 2011) (probable cause defined; exigent‑circumstances balancing)
Commonwealth v. Santiago, 736 A.2d 624 (Pa. Super. 1999) (warrantless home entry requires consent or exigency even with probable cause)
Commonwealth v. Stewart, 740 A.2d 712 (Pa. Super. 1999) (exigency defined: risk to persons or destruction of evidence)
Commonwealth v. Roland, 637 A.2d 269 (Pa. 1994) (factors for assessing exigent circumstances)
Commonwealth v. Pegram, 301 A.2d 695 (Pa. 1973) (flight alone does not establish probable cause)