The Pennsylvania Superior Court reversed an order of the Court of Common Pleas which denied the defendant’s motion to suppress. Several citizens called 911 to report that a pickup truck was driving erratically and might have been involved in a crash. A caller informed dispatch that the car pulled into a driveway, and the driver went inside the house. Police arrived and pounded on the door. When they received no response, they forcibly entered under the pretense that they feared the motorist might have a “medical emergency”. When they rousted the defendant from his sleep, an officer noticed he was drunk and interrogated him. The defendant argued that the entry into his home was illegal, and all evidence recovered must be suppressed. The trial court disagreed. But the Superior Court reversed. It analyzed the factors in Commonwealth v. Roland to determine if the exigent circumstances exception to the warrant requirement applied. The case also turned on the U.S. Supreme Court’s recent holding in Lange v. California. Here, the Superior Court found that the factors did not weigh in favor of the entry and suppressed the evidence.
