Commonwealth v. Haggerty

50 Pa. D. & C.3d 595, 1988 Pa. Dist. & Cnty. Dec. LEXIS 110
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedDecember 22, 1988
Docketno. 3168 September term, 1987
StatusPublished

This text of 50 Pa. D. & C.3d 595 (Commonwealth v. Haggerty) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Haggerty, 50 Pa. D. & C.3d 595, 1988 Pa. Dist. & Cnty. Dec. LEXIS 110 (Pa. Super. Ct. 1988).

Opinion

BERNSTEIN, J.,

On Au-. gust 20, 1987, acting upon information received from an unidentified informant concerning drug ac[596]*596tivity at the location of 7549 Mascher Street, police officer Snead prepared search and seizure warrant no. 15574 requesting a daytime search of the house. The warrant failed to state when the unidentified informant had witnessed drug activity and as conceded by the commonwealth at the motion to suppress heard on June 7 and 8, 1988, the warrant was defective under the clearly established law of Pennsylvania. ■

At the motion to suppress the commonwealth offered to present evidence that Sgt. Perez had recently received the information from the unidentified informant and that the informant said that drug activity was proceeding on August 20, 1987. The commonwealth claims that if the allegations described in the warrant were timely then the search was lawful. Since the proferred testimony was rejected as irrelevant the court assumes for purposes of this opinion that the officers acted in good faith without any intentional misrepresentation and that if permitted Sgt. Perez would have testified credibly as outlined in the offer of proof.

The U. S. Supreme Court in the case of Mapp v. Ohio, 367 U.S. 643 (1961) first established the principal that evidence obtained in violation of the Fourth Amendment of the U. S. Constitution must be suppressed in state court trials. The U. S. Constitution and the Pennsylvania constitution are coterminous in requiring prior judicial approval based on probable cause for any search warrant to issue. This constitutional restraint upon governmental intrusion has been incorporated in rule 2003 of the Pennsylvania Rules of Criminal Procedure which states: “No search warrant shall issue but upon probable cause supported by one or more affidavits, sworn to before the issuing authority.” The rule fur[597]*597ther provides that the issuing authority may not consider any evidence outside of the affidavits.

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Related

Mapp v. Ohio
367 U.S. 643 (Supreme Court, 1961)
Commonwealth v. Gray
503 A.2d 921 (Supreme Court of Pennsylvania, 1986)
Commonwealth v. Edmunds
541 A.2d 368 (Supreme Court of Pennsylvania, 1988)
Commonwealth v. Morris
533 A.2d 1042 (Supreme Court of Pennsylvania, 1987)
Commonwealth v. Melilli
522 A.2d 1107 (Supreme Court of Pennsylvania, 1987)
Commonwealth v. Gray
469 A.2d 169 (Supreme Court of Pennsylvania, 1984)
Commonwealth v. Simmons
301 A.2d 819 (Supreme Court of Pennsylvania, 1973)
Commonwealth v. Milliken
300 A.2d 78 (Supreme Court of Pennsylvania, 1973)

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Bluebook (online)
50 Pa. D. & C.3d 595, 1988 Pa. Dist. & Cnty. Dec. LEXIS 110, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-haggerty-pactcomplphilad-1988.