Commonwealth v. Craig

CourtPennsylvania Superior Court
Writing for the CourtLAZARUS, P.J.
Docket Number2816 EDA 2024,J-A22007-25
Decision Date23 December 2025
CitationCommonwealth v. Craig, 2816 EDA 2024, J-A22007-25 (Pa. Super. Ct. Dec 23, 2025)
PartiesCOMMONWEALTH OF PENNSYLVANIA v. JAQUON CRAIG Appellant

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

Appeal from the Judgment of Sentence Entered June 13, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0007376-2023

BEFORE: LAZARUS, P.J., LANE, J., and STEVENS, P.J.E [*]

MEMORANDUM

LAZARUS, P.J.

Jaquon Craig appeals from the judgment of sentence, entered in the Court of Common Pleas of Philadelphia County, following his convictions of one count each of manufacture, delivery or possession with intent to deliver (PWID),[1] intentional possession of a controlled substance by a person not registered,[2] and possession of marijuana.[3] After careful review, we affirm on the basis of the opinion authored by the Honorable Samantha J. Williams.

The facts and procedural history of this case are as follows:
On June 28, 2023, at approximately 11:00 a[.]m[.] Philadelphia Police Officer Angel Rodriguez ([]Officer Rodriguez[]) initiated a pedestrian stop near 1538 Pratt Street in Philadelphia, Pennsylvania. [See N.T. Waiver Trial,] 3/6/2024, at 10-11. Officer Rodriguez explained that, that morning, he checked the database as he does every day for warrants and noticed an active arrest warrant for [Craig], whom he had known for years. Id. at 11. While on patrol, Officer Rodriguez observed [Craig], ran [Craig]'s name on the MDT in his patrol vehicle, and confirmed the active warrant at that time. Id. Officer Rodriguez then detained [Craig] and contacted the warrant unit to confirm the warrant remained active. Id. The warrant unit agreed that the warrant was active, and [Craig] was placed under arrest. Id. at 12. [Craig] was searched incident to the arrest and recovered from his jacket were 35 small containers with flip caps containing crack cocaine, one medium-size clear plastic bag containing marijuana, and [thirteen] 15-milligram [o]xycodone pills. Id.
On March 6, 2024, the date set for trial in this matter, [Craig filed] a [p]re-[t]rial [m]otion to [s]uppress [the evidence recovered during his arrest]. [At a hearing on the motion,] the trial court heard the testimony of Alessandro Nardi, [Esquire,] an attorney with the Defender Association of Philadelphia ([]Attorney Nardi[]). Id. at 20-21. Attorney Nardi testified that he was the [a]ttorney assigned to [Craig]'s case (MC-51-CR-0009100-2023) ([]Case 9100[]) on June 23, 2023. Id. at 22. Attorney Nardi also testified that [Craig] arrived late to court for Case 9100, and a bench warrant was issued but later lifted. Id. at 32-33. Attorney Nardi further testified that the [j]udge presiding over Case 9100 ordered her court staff to bring in another docket on which [] Craig [was] bench warranted (MC-51-CR-0004927-2023) ([]Case 4927[]) on June 21, 2023[,] and lifted the bench warrant. Id. at 22-23. The docket for Case 4927 reflects two separate [b]ench [w]arrant [h]earing listings - one on June 23, 2023[,] and one on June 30, 2023. [See] Municipal Court Docket CP-51-CR-0004927-2023. The June 23, 2023 docket entry states that there was an "add[-]on approved. . . (BW hearing)." Id. No orders were entered on June 23, 2023[,] on Case 4927. Id. On June 23, 2023, a [p]reliminary [h]earing was scheduled for July 7, 2023. Id. The June 30, 2023 docket entry for Case 4927 states that the [b]ench [w]arrant was lifted, and an order was entered reflecting same. Id.

Trial Court Opinion, 1/21/25, at 2-3.

The trial court denied Craig's motion to suppress, and the case proceeded to a waiver trial. Craig was found guilty on all of the above-mentioned charges. Sentencing was deferred for the preparation of a presentence investigation report and a mental health evaluation. Id. at 1. On June 13, 2024, Craig was sentenced to three years of reporting probation. Craig filed a motion for reconsideration of sentence on June 22, 2024, which was denied by operation of law on October 22, 2024.

Craig filed a timely notice of appeal. Both Craig and the trial court complied with Pa.R.A.P. 1925. Craig raises the following issue on appeal: "Where the only jurisdiction for the search of [] Craig was a search incident to arrest based on an invalid bench warrant, did the [trial] court improperly deny suppression of the narcotics found on [] Craig's person?" Appellant's Brief, at 1.

In his sole issue on appeal, Craig argues that the trial court erred by denying his motion to suppress the evidence because his arrest, and subsequent search, were based solely on an invalid bench warrant. See id. at 7. Specifically, Craig contends that the judge "orally ordered, in open court," that the warrant was lifted on June 23, 2023, five days before Craig's arrest, and that the clerk failed to promptly enter the order lifting the bench warrant on the docket. Id. at 6,7. Thus, Craig posits that the bench warrant was invalid at the time of his arrest. Therefore, Craig contends that, even if Officer Rodriguez operated in good faith in believing that the warrant was valid at the time of the stop and arrest, any evidence gathered due to an arrest on an invalid warrant must be suppressed. Id. at 12, citing Commonwealth v. Edmunds, 586 A.2d 887 (Pa. 1991). Finally, Craig posits that, without any justification for his arrest, the search of his person was unlawful, and the trial court must be reversed to suppress the evidence. See Appellant's Brief, at 16. Our standard and scope of review of the denial of a motion to suppress evidence is well-established:

Appellate review of a suppression decision is limited to the suppression record, considering the evidence presented by the Commonwealth as the prevailing party and any uncontradicted evidence presented by the defense. This Court is bound by the facts as found by the suppression court so long as they are supported by the record, but our review of its legal conclusions is de novo.

Commonwealth v. Valdivia, 195 A.3d 855, 861 (Pa. 2018) (citations omitted). With respect to a suppression court's factual findings, "it is the sole province of the suppression court to weigh the credibility of the witnesses. Further, the suppression court judge is entitled to believe all, part or none of the evidence presented." Commonwealth v. Caple, 121 A.3d 511, 516-17 (Pa. Super. 2015) (citation omitted).

The Fourth Amendment to the United States Constitution and Article I, Section 8 of the Pennsylvania Constitution guarantee the right of the people to be secure in their persons, houses, papers, and possessions from unreasonable searches and seizures. Commonwealth v. Morrison, 166 A.3d 357, 363-64 (Pa. Super. 2017). An officer may conduct a full custodial search of a suspect when the suspect is lawfully arrested. Commonwealth v. Clark, 735 A.2d 1248, 1251 (Pa. 1999), citing Commonwealth v. Long, 414 A.2d 113, 115 (Pa. 1980). However, "[w]hen an officer makes an unlawful arrest, any evidence seized during a search incident to the arrest must be suppressed." Id., citing Commonwealth v. Lovette, 450 A.2d 975, 981 (Pa. 1981).

To be valid, an arrest must be supported by probable cause. In re R.P., 918 A.2d 115 (Pa. Super. 2007). Probable cause to arrest exists when "the facts and circumstances within the police officer's knowledge and of which the officer has reasonably trustworthy information are sufficient in themselves to warrant a person of reasonable caution in the belief that an offense has been committed by the person to be arrested." Commonwealth v. Gwynn, 723 A.2d 143, 148 (Pa. 1998) (emphasis added).

In Edmunds, our Supreme Court declined to adopt the good-faith exception to the exclusionary rule promulgated by the United States Supreme Court in United States v. Leon, 468 U.S. 897 (1984). The Court stated:

[G]iven the strong right of privacy which inheres in Article 1, Section 8, as well as the clear prohibition against the issuance of warrants without probable cause, or based upon defective warrants, the good faith exception to the exclusionary rule would directly clash with those rights of citizens as developed in our Commonwealth over the past 200 years.

Edmunds, 586 A.2d at 901. Specifically, the Court held that, even when police exercised "good faith" in exercising a warrant, evidence seized by a defective search warrant must be suppressed. Id. at 905. The Court further explained that "[t]o adopt a 'good faith' exception to the exclusionary rule, we believe, would virtually emasculate those clear safeguards which have been carefully developed under the Pennsylvania Constitution over the past 200 years." Id. at 899. In Commonwealth v. Johnson, 86 A.3d 182 (Pa. 2014), our Supreme Court reaffirmed Edmunds as controlling precedent and held that evidence was properly suppressed when police arrested the defendant based upon an arrest warrant that was "no longer valid and should have been recalled[.]" Id. at 184.

After a thorough review of the record, the briefs of the parties, the applicable law, and the well-reasoned opinion of Judge Williams, we conclude Craig's issue merits no relief. In denying Craig relief, the trial court concluded that Craig was arrested on an active and valid arrest warrant. See Trial Court Opinion, 1/21/25, at 7. Though contrary to Attorney Nardi's testimony, the docket for Case 4927 "clearly provides that an order lifting [Craig]'s bench warrant was not entered until after the bench warrant hearing on June 30, 2023. Thus, the bench warrant associated with Case 4927 was active and valid on June 28, 2023[,] when Craig was arrested."[4] Id. See Caple, supra. The trial court distinguished Johnson and Edmunds from the current matter, specifically noting that, in Johnson, the search was based on a previously executed warrant that was not...

Get this document and AI-powered insights with a free trial of vLex and Vincent AI

Get Started for Free

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex