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Commonwealth v. Smith

Pennsylvania Superior Court

June 6, 2022

This opinion thoroughly reviews the caselaw about the voluntariness of a defendant’s statement after the police give Miranda warnings. An en banc panel of the Pennsylvania Superior Court vacated the defendant’s convictions of rape and IDSI. The defendant argued that the trial court erred in denying his motion to suppress his statement. The Court found that it could not review the suppression court’s decision because “the suppression judge wholly failed to satisfy the requirements of” Pa. R. Crim. P. Rule 581(I), which requires the motions court to enter its findings of fact and conclusions of law on the record. Thus, the Court remanded for a new suppression hearing.

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