In Commonwealth v. Bellamy, the defendant appealed his conviction of drug charges and asserted the trial court erred in denying a suppression motion. The Pennsylvania Superior Court affirmed. The defendant first argued that the police failed to comply with the knock and announce rule when they entered his hotel room. The Court held that the Commonwealth established an exception to the knock and announce rule. Under the totality of the circumstances, the Commonwealth demonstrated that the officers possessed reasonable suspicion to believe that knock and announce would be futile. The defendant next argued that the wiretap was not supported by reasonable grounds to suspect criminal activity. The Court ruled that based on the facts and the officers’ prior knowledge of the defendant, they possessed reasonable grounds for monitoring.
