Search Warrant • Probable Cause • Confidential Informant • Reliability • Corroboration
Commonwealth v. Manuel, PICS Case No. 17-0573 (Pa. Super. April 7, 2017) Lazarus, J. (28 pages).
Trial court erred in denying motion to suppress drug evidence found in search of house because the affidavit for the search warrant did not establish probable cause where it was based on a tip from a CI who alleged to have been in the house and seen the marijuana but had previously provided information leading to only one arrest that had not yet resulted in a conviction and the police performed no investigation to corroborate or establish the reliability of the tip. Reversed.