Com. v. Rothhaar, D.

CourtSuperior Court of Pennsylvania
DecidedOctober 27, 2025
Docket64 EDA 2024
StatusUnpublished

This text of Com. v. Rothhaar, D. (Com. v. Rothhaar, D.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Rothhaar, D., (Pa. Ct. App. 2025).

Opinion

J-S47041-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37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). J-S47041-24

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

-2- J-S47041-24

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.

-3- J-S47041-24

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).

-4- J-S47041-24

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.

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