Commonwealth v. Young, 2018 Pa. LEXIS 379 (Pa. 2018)

Collective knowledge doctrine expanded to include when an arresting officer lacking firsthand knowledge of the facts is working with the investigating officer with firsthand knowledge of the probable cause or reasonable suspicion.

The defendant moved to suppress evidence obtained during the execution of a search warrant by an officer who did not have any firsthand knowledge of the facts creating probable cause for the warrant. The trial court denied the defendant’s motion to suppress. The Superior Court overturned, stating that Pennsylvania has a limited interpretation of the collective knowledge doctrine under the vertical approach. The Supreme Court overturned the Superior Court, stating that it is not expanding the collective knowledge doctrine to adopt a horizontal approach. Rather, the court determined that when officers are acting together to execute a warrant, the Fourth Amendment is not violated if the investigating officer with firsthand knowledge would have inevitably ordered the seizure be effectuated.

 

Case Law Alerts, 2nd Quarter, April 2018

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