Commonwealth v. Dunkins, A., Aplt.

CourtSupreme Court of Pennsylvania
DecidedNovember 17, 2021
Docket45 MAP 2020
StatusPublished

This text of Commonwealth v. Dunkins, A., Aplt. (Commonwealth v. Dunkins, A., Aplt.) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Dunkins, A., Aplt., (Pa. 2021).

Opinion

[J-3-2021] IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT

BAER, C.J., SAYLOR, TODD, DONOHUE, DOUGHERTY, WECHT, MUNDY, JJ.

COMMONWEALTH OF PENNSYLVANIA, : No. 45 MAP 2020 : Appellee : Appeal from the Order of the : Superior Court dated February 12, : 2020 at No. 1003 EDA 2019 v. : Affirming the Judgment of Sentence : of the Northampton County Court of : Common Pleas, Criminal Division, ALKIOHN DUNKINS, : dated January 4, 2019 at No. CP- : 48-CR-1577-2017. Appellant : : ARGUED: March 9, 2021

OPINION

JUSTICE DOUGHERTY1 DECIDED: November 17, 2021 We granted review to determine whether the trial court erred by denying

suppression of wireless internet network (WiFi) connection records obtained by police

without a warrant from the Information Technology Department of Moravian College. For

the following reasons, we conclude this search was constitutionally permissible, and

accordingly, we affirm the order of the Superior Court.

At approximately 2:00 a.m. on February 2, 2017, two masked men posed as

campus police to gain entry to the dorm room shared by Greg Farina and William Reilley

in the Hassler dormitory building on the Moravian College Campus in Bethlehem. The

men held Farina and Reilley at gunpoint and stole $1,000 and a jar of marijuana from

Reilley’s footlocker. Reilley reported the robbery to campus officials around 11:00 a.m.

1 The matter was reassigned to this author. and, thereafter, campus police requested that Moravian College’s Director of Systems

Engineering, Christopher Laird, analyze its WiFi connection records to compile a list of

students logged on to the WiFi in the Hassler building at the time of the robbery. Laird

discovered only three Moravian College students were logged on to the campus WiFi at

that location who did not reside in the Hassler building; two were females and the other

was appellant, Alkiohn Dunkins.

Campus police relayed this information to Detective James Ruvolo of the

Bethlehem Police Department. In the course of his investigation, Detective Ruvolo

interviewed Reilley, appellant, and Colin Zarecki, another Moravian College student.

Reilley told Detective Ruvolo he suspected appellant participated in the robbery because

appellant previously stole from him by failing to pay for marijuana, while appellant denied

being involved in the robbery and told Detective Ruvolo he had not entered the Hassler

building since October 2016. Colin Zarecki told Detective Ruvolo that on February 3,

2017, the day after the robbery, appellant bragged to him about money he stole by posing

as a campus police officer. Based on the above information, appellant was arrested and

charged with robbery, conspiracy to commit robbery, receiving stolen property, and

simple assault.2

Prior to trial, appellant filed a motion to suppress in which he claimed the campus

police conducted an illegal search by obtaining the Hassler building WiFi connection

records without a warrant. During a hearing on the motion, Laird testified Moravian

College students access the college’s WiFi network by entering their individual

usernames and passwords, and that students may choose to have their devices

automatically log on to the network without having to re-enter their username and

2 18 Pa.C.S. §3701(a)(1)(ii), 18 Pa.C.S. §903, 18 Pa.C.S. §3925(a), and 18 Pa.C.S.

§2701(a)(1), respectively.

[J-3-2021] - 2 password each time they want WiFi access. The parties also acknowledged appellant

assented to Moravian College’s Computing Resources Policy. The policy provided: Logging in to or otherwise connecting to the campus network implies acceptance of this Moravian College . . . Policy[.] *** The institution's computing equipment and network resources are dedicated to Moravian business to enhance and support the educational mission of Moravian College. These resources include all computers, workstations, and multi-user computer systems along with local area networks and wireless networks via the Internet. *** [A]ny data transmitted over institutional assets or connections made through institutional assets are included. The institution has the right to inspect information stored on its system at any time, for any reason, and users cannot and should not have any expectation of privacy with regard to any data, documents, electronic mail messages, or other computer files created or stored on computers within or connected to the institution's network. All Internet data composed, transmitted, or received through the Internet's computer system is considered part of the institution's records and, as such, subject at any time to disclosure to institutional officials, law enforcement, or third parties[.] Moravian College’s Computing Resources Policy (“Computing Resources Policy”) -

Defense Exhibit 1 (emphasis added).3 The trial court denied appellant’s suppression

motion and a jury later convicted him of the aforementioned charges. Thereafter, the trial

court denied appellant’s motion for extraordinary relief and sentenced him to an

aggregate term of five to ten years’ imprisonment. Following the denial of his post-

sentence motion, appellant filed a direct appeal in the Superior Court.

In a unanimous, published opinion, a three-judge panel of the Superior Court

affirmed the trial court’s denial of suppression. Commonwealth v. Dunkins, 229 A.3d 622

3 The Computing Resources Policy was included in Moravian’s Student Handbook, which

is provided to all students; all students must acknowledge they received and reviewed the handbook before enrolling at Moravian College.

[J-3-2021] - 3 (Pa. Super. 2020), allocatur granted, 237 A.3d 415 (Pa. 2020) (per curiam). The panel

first rejected appellant’s contention this case is controlled by Carpenter v. United States,

___ U.S. ___, 138 S.Ct. 2206 (2018). The panel ably explained the decision as follows: [In Carpenter,] the U.S. Supreme Court found law enforcement officials improperly acquired Carpenter’s CSLI[4] without a warrant. In that case, Carpenter was a suspect in a string of armed robberies. Officers compelled Carpenter's wireless carriers to provide a record of Carpenter’s historical CSLI for a four-month period, allowing the officers to track Carpenter’s movements during the time when the robberies had occurred. Carpenter, 138 S.Ct. at 2212.

Although the Court recognized an individual has a reduced expectation of privacy in information knowingly shared with another, the Court found the “nature of the particular documents sought” must be considered to determine whether there is a legitimate expectation of privacy. Id. at 2219. The Supreme Court recognized that modern cell phones generate time- stamped records known as CSLI when the phone continuously scans for the best signal from the closest cell site and connects to that cell site. Id. at 2211. Such information is collected by wireless carriers for business purposes to improve their network and to bill customers who incur “roaming” charges through another carrier’s network. Id. The Supreme Court also noted that an electronic device will log CSLI simply through the user’s operation of the phone on the carrier network “without any affirmative act on the part of the user beyond powering up.” Id. at 2220.

Emphasizing that “cell phones and the services they provide are such a pervasive and insistent part of daily life that carrying one is indispensable to participation in modern society,” the Supreme Court concluded that the officers invaded Carpenter’s reasonable expectation of privacy in his physical movements by collecting the historical CSLI without a warrant as

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