Commonwealth v. Carter

After the trial court granted Wallace’s suppression motion, the Commonwealth appealed. The Superior Court reversed. The Court ruled that the suppression court ignored the stated basis for the suppression motion—that Carter’s physical and psychological state was such that he could not knowingly, intelligently, and voluntarily waive his Miranda rights— and instead sua sponte determined that “under the circumstances, a ‘palpable ambiguity’ existed as to the reason for the interrogation; was [Carter] being questioned as a suspect or a victim[?]” The Court concluded that the suppression court erred by suppressing evidence on grounds not asserted in Carter’s motion.