Commonwealth v. Craig
| Court | Pennsylvania Superior Court |
| Writing for the Court | LAZARUS, P.J. |
| Docket Number | 2816 EDA 2024,J-A22007-25 |
| Decision Date | 23 December 2025 |
| Citation | Commonwealth v. Craig, 2816 EDA 2024, J-A22007-25 (Pa. Super. Ct. Dec 23, 2025) |
| Parties | COMMONWEALTH OF PENNSYLVANIA v. JAQUON CRAIG Appellant |
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.
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, 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 [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...
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