federal good faith exception (Pennsylvania) · Go Syfert
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federal good faith exception in Pennsylvania

9 Pennsylvania opinions name it 2 courts 2009–2024 2 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Commonwealth v. Edmundsgreen
pa · 1991 · cited in 6 Pennsylvania opinions naming this issue, 2010–2024
2 sentences

2024President Judge Lazarus and Judge Lane join this dissenting opinion. ____________________________________________ See, e.g., Commonwealth v. Alexander, 243 A.3d 177 , 202 (Pa. 2020) (holding the Pennsylvania constitution affords greater protection than the federal constitution for Pennsylvanians subjected to warrantless car searches); Commonwealth v. Edmunds, 586 A.2d 887, 905-06 (Pa. 1991) (declining to adopt the federal good faith exception to the Pennsylvania constitution’s warrant requirement). -6-

2020Specifically, the Commonwealth invoked the federal good-faith exception to the exclusionary rule.3 Notably, the Commonwealth’s brief before the Superior Court offered the following circumspection: It would be disingenuous of the Commonwealth to fail to acknowledge the Pennsylvania Supreme Court in Commonwealth v. Edmunds, 586 A.2d 887 (Pa. 1991) rejected Leon as an Article 1, Section 8 matter, and holding that Section 8 “does not incorporate a ‘good faith’ exception to the exclusionary rule.” Edmunds, 586 A.2d at 905-06 .

46
Commonwealth v. Carpergreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Commonwealth v. Carper, 172 A.3d 613, 620 (Pa.Super. 2017), appeal denied, 184 A.3d 540 (Pa. 2018), citing Commonwealth v. Frederick, 124 A.3d 748, 756 (Pa.Super. 2015), appeal denied, 138 A.3d 2 (Pa. 2016) (holding that the -8- J.

11
Commonwealth v. Frederickgreen
pasuperct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Commonwealth v. Carper, 172 A.3d 613, 620 (Pa.Super. 2017), appeal denied, 184 A.3d 540 (Pa. 2018), citing Commonwealth v. Frederick, 124 A.3d 748, 756 (Pa.Super. 2015), appeal denied, 138 A.3d 2 (Pa. 2016) (holding that the -8- J.

11
Commonwealth, Aplt. v. Shabezz, S.green
pa · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019“Evidence constitutes fruit of the poisonous tree, and must be suppressed, if it was obtained by ‘exploitation’ of the illegality … and so long as the taint of that illegality has not been purged.” Commonwealth v. Shabezz, 166 A.3d 278, 290 (Pa. 2017).

11
Commonwealth v. Edmundsgreen
pa · 1988 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
2 sentences

2017Commonwealth v. Edmunds, 373 Pa.Super. 384 , 541 A.2d 368, 372 (1988), rev’d, 526 Pa. 374 , 586 A.2d 887 (1991).

2017Commonwealth v. Edmunds, 373 Pa.Super. 384 , 541 A.2d 368, 372 (1988), rev’d, 526 Pa. 374 , 586 A.2d 887 (1991).

11
Commonwealth v. Johnsongreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015Commonwealth v. Johnson, 86 A.3d 182, 184 (Pa. 2014); see also Commonwealth v. Edmunds, 586 A.2d 887, 899 (Pa. 1991) (rejecting the federal good faith exception to the exclusionary rule as it would emasculate essential rights guaranteed by the Pennsylvania Constitution). *Retired Senior Judge assigned to the Superior Court.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Herring v. United States green
scotus · 2009
2 sentences

2010Notably, the majority’s analysis suggests a movement away from a narrow construction of exceptions to the warrant requirement, as it references a decision of the United States Supreme Court applying the federal good-faith exception to the warrant requirement as supportive of its position, see Majority Opinion, Op. at 144, 995 A.2d at 1153 (citing Herring v. United States, 555 U.S. 135 , 129 S.Ct. 695 , 172 L.Ed.2d 496 (2009)), even though this Court previously has maintained that the exception does not pertain under Pennsylvania constitutional law.

2010Notably, the majority’s analysis suggests a movement away from a narrow construction of exceptions to the warrant requirement, as it references a decision of the United States Supreme Court applying the federal good-faith exception to the warrant requirement as supportive of its position, see Majority Opinion, Op. at 144, 995 A.2d at 1153 (citing Herring v. United States, 555 U.S. 135 , 129 S.Ct. 695 , 172 L.Ed.2d 496 (2009)), even though this Court previously has maintained that the exception does not pertain under Pennsylvania constitutional law.

22009–2010
United States v. Robert Franz green
ca3 · 2014
1 sentence

2021A classic example of the good-faith exception is found in United States v. Franz, 772 F.3d 134 (3d Cir. 2014).

12021–2021
Commonwealth v. Harris green
pa · 2016
1 sentence

2020Commonwealth v. Carper, 172 A.3d 613, 620 (Pa.Super. 2017), appeal denied, 184 A.3d 540 (Pa. 2018), citing Commonwealth v. Frederick, 124 A.3d 748, 756 (Pa.Super. 2015), appeal denied, 138 A.3d 2 (Pa. 2016) (holding that the -8- J.

12020–2020
Commonwealth v. Brown neutral
pa · 2018
1 sentence

2020Commonwealth v. Carper, 172 A.3d 613, 620 (Pa.Super. 2017), appeal denied, 184 A.3d 540 (Pa. 2018), citing Commonwealth v. Frederick, 124 A.3d 748, 756 (Pa.Super. 2015), appeal denied, 138 A.3d 2 (Pa. 2016) (holding that the -8- J.

12020–2020

Where else courts name it

TX 17 (1991–2019) PA 9 (2009–2024) WA 9 (2003–2020) NM 9 (1993–2023) IN 7 (1991–2018) UT 4 (1991–2010) NC 3 (2017–2026) NJ 3 (2015–2019) MA 2 (1989–2014) MN 2 (2015–2016) WI 2 (2009–2012) ND 2 (1999–2004)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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