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9 Pennsylvania opinions name it 1 courts 2019–2026 8 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.
| Case | Followed | Cited |
|---|---|---|
Commonwealth v. Perelgreen2 sentences2025This Court has cautioned, however, that “the inevitable discovery doctrine is not a substitute for the warrant requirement[, and the Commonwealth] must demonstrate that the evidence would have been discovered absent the police misconduct, not simply that [law enforcement] somehow could have lawfully discovered it.” Perel, 107 A.3d at 196 (emphases in original). 2025Stated simply, the inevitable discovery doctrine is not a substitute for the warrant requirement. - 33 - Id. at 196 (quotation marks and brackets omitted) (citing Edmunds, 586 A.2d at 899 ); see also, e.g., Commonwealth v. Mackey, 177 A.3d 221, 228 (Pa. Super. 2017) (stating that “information developed after a police- citizen encounter moves from consensual to coercive cannot be used to justify the detention”) (emphasis in original; citations omitted); Commonwealth v. Arnold, 932 A.2d 143, 144, 149 (Pa. Super. 2007) (concluding that police could not retroactively justify the search of a casual | 9 | 9 |
Commonwealth v. MacKeygreen1 sentence2025Stated simply, the inevitable discovery doctrine is not a substitute for the warrant requirement. - 33 - Id. at 196 (quotation marks and brackets omitted) (citing Edmunds, 586 A.2d at 899 ); see also, e.g., Commonwealth v. Mackey, 177 A.3d 221, 228 (Pa. Super. 2017) (stating that “information developed after a police- citizen encounter moves from consensual to coercive cannot be used to justify the detention”) (emphasis in original; citations omitted); Commonwealth v. Arnold, 932 A.2d 143, 144, 149 (Pa. Super. 2007) (concluding that police could not retroactively justify the search of a casual | 1 | 1 |
Commonwealth v. Arnoldgreen1 sentence2025Stated simply, the inevitable discovery doctrine is not a substitute for the warrant requirement. - 33 - Id. at 196 (quotation marks and brackets omitted) (citing Edmunds, 586 A.2d at 899 ); see also, e.g., Commonwealth v. Mackey, 177 A.3d 221, 228 (Pa. Super. 2017) (stating that “information developed after a police- citizen encounter moves from consensual to coercive cannot be used to justify the detention”) (emphasis in original; citations omitted); Commonwealth v. Arnold, 932 A.2d 143, 144, 149 (Pa. Super. 2007) (concluding that police could not retroactively justify the search of a casual | 1 | 1 |
Commonwealth v. Demshockgreen1 sentence2025Stated simply, the inevitable discovery doctrine is not a substitute for the warrant requirement. - 33 - Id. at 196 (quotation marks and brackets omitted) (citing Edmunds, 586 A.2d at 899 ); see also, e.g., Commonwealth v. Mackey, 177 A.3d 221, 228 (Pa. Super. 2017) (stating that “information developed after a police- citizen encounter moves from consensual to coercive cannot be used to justify the detention”) (emphasis in original; citations omitted); Commonwealth v. Arnold, 932 A.2d 143, 144, 149 (Pa. Super. 2007) (concluding that police could not retroactively justify the search of a casual | 1 | 1 |
Commonwealth v. Baileygreen1 sentence2022Commonwealth v. King, 259 A.3d 511, 522 (Pa.Super. 2021) (quoting Commonwealth v. Bailey, 986 A.2d 860, 862 (Pa.Super. 2009), appeal denied, 606 Pa. 660 , 995 A.2d 350 (2010)). - 12 - “[T]he inevitable discovery doctrine is not a substitute for the warrant requirement. | 1 | 1 |
Com. v. King, C.green1 sentence2022Commonwealth v. King, 259 A.3d 511, 522 (Pa.Super. 2021) (quoting Commonwealth v. Bailey, 986 A.2d 860, 862 (Pa.Super. 2009), appeal denied, 606 Pa. 660 , 995 A.2d 350 (2010)). - 12 - “[T]he inevitable discovery doctrine is not a substitute for the warrant requirement. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Commonwealth v. Valentine
green
2 sentences2024Police must demonstrate that the evidence would have been discovered absent the police misconduct, not simply that they somehow could have lawfully discovered it.” Commonwealth v. Perel, 107 A.3d 185, 196 (Pa.Super. 2014), appeal denied, 633 Pa. 749 , 124 A.3d 309 (2015) (emphasis in original). 2024Police must demonstrate that the evidence would have been discovered absent the police misconduct, not simply that they somehow could have lawfully discovered it.” Commonwealth v. Perel, 107 A.3d 185, 196 (Pa.Super. 2014), appeal denied, 633 Pa. 749 , 124 A.3d 309 (2015) (emphasis in original). | 3 | 2022–2024 |
Com. v. Perel
neutral
2 sentences2024Police must demonstrate that the evidence would have been discovered absent the police misconduct, not simply that they somehow could have lawfully discovered it.” Commonwealth v. Perel, 107 A.3d 185, 196 (Pa.Super. 2014), appeal denied, 633 Pa. 749 , 124 A.3d 309 (2015) (emphasis in original). 2024Police must demonstrate that the evidence would have been discovered absent the police misconduct, not simply that they somehow could have lawfully discovered it.” Commonwealth v. Perel, 107 A.3d 185, 196 (Pa.Super. 2014), appeal denied, 633 Pa. 749 , 124 A.3d 309 (2015) (emphasis in original). | 3 | 2022–2024 |
Commonwealth v. Edmunds
green
1 sentence2025Stated simply, the inevitable discovery doctrine is not a substitute for the warrant requirement. - 33 - Id. at 196 (quotation marks and brackets omitted) (citing Edmunds, 586 A.2d at 899 ); see also, e.g., Commonwealth v. Mackey, 177 A.3d 221, 228 (Pa. Super. 2017) (stating that “information developed after a police- citizen encounter moves from consensual to coercive cannot be used to justify the detention”) (emphasis in original; citations omitted); Commonwealth v. Arnold, 932 A.2d 143, 144, 149 (Pa. Super. 2007) (concluding that police could not retroactively justify the search of a casual | 1 | 2025–2025 |
Com. v. Bailey
neutral
1 sentence2022Commonwealth v. King, 259 A.3d 511, 522 (Pa.Super. 2021) (quoting Commonwealth v. Bailey, 986 A.2d 860, 862 (Pa.Super. 2009), appeal denied, 606 Pa. 660 , 995 A.2d 350 (2010)). - 12 - “[T]he inevitable discovery doctrine is not a substitute for the warrant requirement. | 1 | 2022–2022 |