Suppression of Evidence from Car Search

Commonwealth v. Massey, PICS Case No. 16-1245 (C.P. Crawford Aug. 19, 2016) Spataro, J. (8 pages).

An individual with outstanding warrants went to the courthouse to submit payment with a bad check, and was taken into custody. The detective assigned to assist with the bad check went to the parked vehicle in which the individual arrived, and observed documents in plain view that could be relevant. The driver of the car, defendant’s wife, was likewise taken into custody on an outstanding warrant, the vehicle impounded, and search warrant obtained. Defendant sought to suppress the evidence obtained from the search on grounds that the police had lacked probable cause, which the court refuted based on the unfolding of events and on the Vehicle Code. Defendant’s motion to suppress was denied.