Com. v. Rothhaar, D.

Superior Court of Pennsylvania·Decided October 27, 2025·No. 64 EDA 2024·Unpublished

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

v. :

:

DAVID MORGAN ROTHHAAR :

:

Appellant : No. 64 EDA 2024

Appeal from the Judgment of Sentence Entered November 29, 2023 In the Court of Common Pleas of Bucks County Criminal Division at No(s): CP-09-CR-0003675-2022

BEFORE: KUNSELMAN, J., SULLIVAN, J., and BECK, J. MEMORANDUM BY KUNSELMAN, J.: FILED OCTOBER 27, 2025 I. Introduction

David Rothhaar appeals from the judgment of sentence imposing four to eight years of incarceration, following his convictions for burglary, criminal trespass, and possession of an instrument of a crime. 1 Rothhaar claims the lower court should have granted his motion to suppress the Commonwealth’s evidence or, alternatively, that the Commonwealth witness Russell Mitchell should not have been allowed to testify. Because we find that the suppression claims are waived and that his evidentiary issue has no merit, we affirm.

II. Factual & Procedural Background On June 28, 2022, around 9:40 p.m., Rothhaar broke into the home of Robert Capriotti. Mr. Capriotti heard Rothhaar making noise in the upstairs

rooms and running down the steps. Mr. Capriotti called 911 at 9:46 p.m. Mr.

1 18 Pa.C.S.A. §§ 907(a), 3502(a)(1)(ii), 3503(a)(1)(ii), and 3921(a).

Capriotti never saw Rothhaar in the house, but Rothhaar left his DNA on a windowsill in Mr. Capriotti’s garage.

At 9:53 p.m., in response to the 911 call, a police sergeant drove into Mr. Capriotti’s neighborhood. He saw Rothhaar crossing the street two doors down from the Capriotti house. Rothhaar was the only person outside at that hour of the night.

The sergeant suspected that Rothhaar might be the burglar, because he carried a backpack in his hand. The sergeant knew, from many prior burglary investigations, that burglars typically carry bags with them to hide their tools and stolen goods. The sergeant stopped Rothhaar to investigate if he was involved with the break-in. Police then learned of a warrant for Rothhaar’s arrest, arrested him, and searched his backpack. Inside was a small crowbar, a metal tool, and a pair of gloves. The gloves belonged to Mr. Capriotti.

Once at the police station, Rothhaar provided investigators with a DNA sample, which matched the DNA found on Mr. Capriotti’s windowsill. The Commonwealth charged Rothhaar with burglary and related offenses.

Rothhaar filed a motion to suppress the Commonwealth’s evidence. He contended that the sergeant detained him “in violation of his rights as secured to him by the Fourth and Fourteenth Amendment to the United States

constitution[2] and Article I, § 8 of the Pennsylvania constitution [3].” Omnibus Pre-Trial Motion at 2. Critically, the motion did not claim greater protection under Article I, § 8 of the state constitution than the protections that the Fourth Amendment confers. Nor did the motion claim the suppression court should depart from federal jurisprudence in any manner. See id. at 2-3. In other words, Rothhaar’s suppression motion treated the federal and state constitutional protections as coextensive.

On January 9, 2023, the suppression court held an evidentiary hearing on the motion. The Commonwealth presented testimonial and video evidence revealing the above facts. A week later, the suppression court ruled that the sergeant lacked reasonable suspicion to detain Rothhaar for an investigative detention. It entered an order suppressing the Commonwealth’s evidence, as well as Rothhaar’s various statements to the police.

The Commonwealth moved for reconsideration. Among other issues, the prosecution contended the attenuation doctrine, as defined and applied in

2 “The right of the people to be secure in their persons, houses, papers, and

effects, against unreasonable searches and seizures, shall not be violated . . . .” U.S. Const. amnd. IV.

3 “The people shall be secure in their persons, houses, papers and possessions from unreasonable searches and seizures . . . .” Pa. Const. art. I, § 8.

Utah v. Strieff, 579 U.S. 232 (2016)4, allowed for admission of the evidence, even if the police lacked reasonable suspicion to detain Rothhaar.

Rothhaar filed nothing in opposition to the Commonwealth’s motion for reconsideration. The suppression court granted reconsideration. On January 31, 2023, the court conducted a second suppression hearing, where it received additional testimony and evidence.

At the close of the second hearing, the parties argued over admissibility of a video from the sergeant’s dashboard camera, which the sergeant did not realize existed until a day before the second hearing. See N.T., 1/31/23, at 73-81. The suppression court deemed the dashboard video to be inadmissible under the discovery rules.

The Commonwealth also claimed that, even if there was no reasonable suspicion to stop Rothhaar, the suppression court should refuse to exclude its evidence, based on the attenuation doctrine and Strieff. See id. at 82-87. The Commonwealth argued that the facts of Strieff were identical to this case. Because Rothhaar had a valid arrest warrant when the sergeant detained him, the Commonwealth suggested the warrant attenuated whatever constitutional taint the evidence suffered from the unreasonable investigative detention.

4 See Utah v. Strieff, 579 U.S. 232 (2016) (holding that, under the Fourth

Amendment, evidence seized during a search incident to a suspect’s arrest is admissible, because the discovery of an outstanding arrest warrant for the suspect attenuated the connection between an unlawful investigative stop and the seizure of incriminating evidence during the search incident to that arrest).

In response, counsel for Rothhaar said, “I don’t think Strieff affects this court’s ruling.” Id. at 87. “[A]lthough [Strieff] is a United States Supreme Court case, Pennsylvania typically provides greater protection for its citizens. And it’s clear that Strieff has not yet been adopted in Pennsylvania.” Id. But, instead of analyzing the multifactor test of Commonwealth v. Edmunds, 586 A.2d 887 (Pa. 1991), and asking the suppression court to depart from the Fourth Amendment jurisprudence as articulated in Strieff, defense counsel argued that Strieff was distinguishable on its facts from Rothhaar’s case. See id. at 87-91.

Furthermore, defense counsel never discussed Edmunds during her argument to the suppression court. Instead, she referred the court to Hudson v. Michigan, 547 U.S. 586 (2006) (holding that violation of the “knock-and- announce” rule when executing search warrant does not require suppression of evidence discovered during the unannounced search). See id. at 88. Hence, like his Omnibus Pre-Trial Motion, Rothhaar’s post-hearing argument on the attenuation doctrine treated the protections of the Fourth Amendment and Article I, § 8 as coextensive.

The Commonwealth then rebutted defense counsel’s implication that Pennsylvania courts needed to adopt Strieff in order for it to apply. In doing so, the prosecutor made the only reference to Edmunds. He did so to explain how the defense could have made a departure argument to the suppression court, if she desired to present such a claim. The prosecuting attorney said:

in terms of the Strieff case . . . the Fourth Amendment of the United States constitution is adopted by Pennsylvania. There would need to be a specific finding that Utah v. Strieff is not applicable under the Pennsylvania constitution, not that it does not apply. It has to be the other way around.

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