gunshot residue test (Pennsylvania) · Go Syfert
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gunshot residue test in Pennsylvania

7 Pennsylvania opinions name it 1 courts 2016–2026 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 (17)

CaseFollowedCited
Commonwealth v. McCarthygreen
pasuperct · 2003 · cited in 2 Pennsylvania opinions naming this issue, 2020–2020
2 sentences

2020See McCarthy, 820 A.2d at 760 .

2020See McCarthy, 820 A.2d at 760 .

22
Commonwealth v. Natividad, R., Aplt.green
pa · 2019 · cited in 2 Pennsylvania opinions naming this issue, 2020–2020
2 sentences

2020Appellant maintains: (1) he was in a hospital room; (2) he was questioned by two police officers in uniform9 who had already formed the belief his wound was self-inflicted; (3) he was subjected to “a ruse clearly designed to pressure [him] into incriminating himself,” Appellant’s Brief at 10, 14, (4) the “custodial nature of the encounter was strengthened by” Officer Moffatt’s directive — rather than a request — to perform a gunshot residue test, id. at 13-14; and (5) no reasonable person in his situation would feel he was free to leave or refuse the gunshot residue test.

2020Appellant maintains: (1) he was in a hospital room; (2) he was questioned by two police officers in uniform9 who had already formed the belief his wound was self-inflicted; (3) he was subjected to “a ruse clearly designed to pressure [him] into incriminating himself,” Appellant’s Brief at 10, 14, (4) the “custodial nature of the encounter was strengthened by” Officer Moffatt’s directive — rather than a request — to perform a gunshot residue test, id. at 13-14; and (5) no reasonable person in his situation would feel he was free to leave or refuse the gunshot residue test.

22
Commonwealth v. Wrecksgreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026In response, Kuhn confessed to police that he had shot his wife in the midst of an argument.3 Consequently, police arrested Kuhn and the Commonwealth charged him with criminal attempt (criminal homicide), aggravated assault, ____________________________________________ required to examine the record, present issues, and request permission to withdraw, there are also significant differences, as explained infra. See Commonwealth v. Wrecks, 931 A.2d 717, 721-22 (Pa. Super. 2007). 3 During the evidentiary hearing conducted pursuant to the underlying PCRA petition, plea counsel testified that in an

11
Com. v. Harper, D.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See id. at 1234, 1239.

11
Commonwealth v. Johnsongreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019See e.g., Commonwealth v. Johnson, 180 A.3d 474, 478 (Pa. Super. 2018), appeal denied, 205 A.3d 315 (Pa. 2019) (holding that the appellant’s attempts to enhance his argument by asserting that the Commonwealth failed to present any corroborating evidence to support a victim's in-court identification testimony did not establish that the identity evidence was insufficient).

11
Rambert v. Dep't of Corr.green
pa · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Appellant points to absences in the evidence presented (the lack of a recovered weapon and lack of a gunshot residue test), but this Court must review the sufficiency of “all evidence actually received.” Commonwealth v. Patterson, 180 A.3d 1217, 1230 (Pa. Super. 2018).

11
Commonwealth v. Johnsongreen
pa · 2019 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019See e.g., Commonwealth v. Johnson, 180 A.3d 474, 478 (Pa. Super. 2018), appeal denied, 205 A.3d 315 (Pa. 2019) (holding that the appellant’s attempts to enhance his argument by asserting that the Commonwealth failed to present any corroborating evidence to support a victim's in-court identification testimony did not establish that the identity evidence was insufficient).

11
Commonwealth v. Johnsongreen
pa · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019See id.

11
Jones v. Stategreen
mdctspecapp · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

11
State v. Kygergreen
tenncrimapp · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

11
United States v. Johnsongreen
ca5 · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

11
People v. Allengreen
illappct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

11
Birchfield v. N. Dakota. William Robert Bernardgreen
scotus · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016See Birchfield, 136 S.Ct. at 2177 .

11
State v. Beasleygreen
arizctapp · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

11
State v. Parsonsgreen
mo · 1974 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

11
Riley v. Cal. United Statesgreen
· 2014 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016We must next assess “the degree to which [the gunshot residue test] is needed for the promotion of legitimate governmental interests.” Riley, 134 S.Ct. at 2484 (internal quotations and citations omitted).

11
Ray v. Stategreen
ark · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

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
Strickland v. State green
ga · 1981
1 sentence

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

12016–2016
State v. Riley green
wva · 1997
2 sentences

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

12016–2016
Dharminder Vir Sen v. The State of Wyoming green
wyo · 2013
1 sentence

2016See, e.g., Jones v. State, 213 Md.App. 483 , 74 A.3d 802, 813 (2013) (“we conclude that the [gunshot residue] evidence was properly collected in the course of a reasonable search incident to [the defendant’s] lawful arrest, for which no warrant was required”); Sen v. State, 301 P.3d 106 (Wy.2013) (“in light of the minimal intrusion paused by the swab for gunshot residue and the easy destructibility of such evidence, ad *802 ministration of the gunshot residue test was a valid search incident to arrest”): People v. Allen, 376 Ill.App.3d 511 , 314 Ill.Dec. 934 , 875 N.E.2d 1221, 1228 (2007) ("[b

12016–2016
Commonwealth v. Westwood green
pa · 1936
2 sentences

2016As such, we will not discuss the temporal limits to the exception. 8 .Within Pennsylvania case law, the earliest reference to a gunshot residue test that this Court Was able to discover was in the 1936 Pennsylvania Supreme Court opinion Commonwealth v. Westwood, 324 Pa. 289 , 188 A. 304 (1936).

2016As such, we will not discuss the temporal limits to the exception. 8 .Within Pennsylvania case law, the earliest reference to a gunshot residue test that this Court Was able to discover was in the 1936 Pennsylvania Supreme Court opinion Commonwealth v. Westwood, 324 Pa. 289 , 188 A. 304 (1936).

12016–2016

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 6105 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 21 (1992–2025) OH 12 (2001–2024) PA 7 (2016–2026) TN 7 (1989–2014) MO 7 (1978–1994) GA 6 (2002–2026) NC 5 (1981–2017) TX 4 (2004–2011) CT 4 (2011–2025) SC 4 (2007–2015) CA 3 (2014–2021) FL 2 (2002–2004) ID 2 (2018–2018) MS 2 (2017–2023) KS 2 (2008–2022)

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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