Law School Case Brief
Commonwealth v. Johnson - 624 Pa. 325, 86 A.3d 182 (2014)
The Supreme Court of Pennsylvania has held that Pa. Const. art. I, § 8 does not incorporate a "good faith" exception to the exclusionary rule. Given the strong right of privacy which inheres in art. I, § 8, as well as the clear prohibition against the issuance of warrants without probable cause, or based upon defective warrants, the good faith exception to the exclusionary rule would directly clash with those rights of citizens as developed in Pennsylvania over the years. Therefore, the exclusionary remedy is deemed available even in a situation where police acted in good faith.
On March 8, 2010, appellee Richard Allen Johnson was a passenger in a vehicle in Wilkes-Barre which was stopped by State Trooper James Knott, who had previously received a radio communication that the vehicle in question had been involved in a drug transaction, and who then observed that the vehicle had a broken tail light. Upon requesting identification and processing Johnson's name through his patrol car computer, Trooper Knott received a "hit" message advising that there was an active arrest warrant for Johnson. Trooper Knott then placed Johnson under arrest and conducted a pat-down search during which he discovered thirty-seven packets of suspected heroin, two cell phones and $1674.00 in cash. Trooper Knott placed Johnson in the back of a police car and transported him to the police barracks, where he read Johnson the Miranda warnings. Johnson made several statements to Trooper Knott. In one statement, Johnson indicated that he is a drug dealer and that the driver of the vehicle bought drugs from him. In a later statement, Johnson claimed he is a user of drugs, not a seller, and that the cash he carried at the time of the arrest and pat-down search was a tax refund. Trooper Knott subsequently determined that the warrant notification he relied upon when he arrested Johnson was no longer valid and should have been recalled, since it had previously been served on Johnson nine days earlier, on February 27, 2010. The trial court granted Johnson's motion and ordered suppression of the evidence under Article I, Section 8. The court found as a fact that Trooper Knott had acted in good faith in arresting Johnson on the basis of what Knott mistakenly believed was an active warrant, but the court reasoned that there is no good faith exception to the exclusionary rule under the Pennsylvania Constitution. The Superior Court affirmed.
Did the Superior Court err in affirming the trial court's suppression of physical evidence seized incident to an arrest based on an invalid (expired) arrest warrant, where the police officer reasonably and in good faith believed that the arrest warrant was valid?
The Court held that the Superior Court did not err in affirming the trial court's decision. The trial court properly suppressed physical evidence seized incident to an arrest based on an invalid warrant, even though the police officer reasonably and in good faith believed that the expired arrest warrant was valid, because there was no good faith exception to the exclusionary rule under Pa. Const. art. I, § 8.
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