## Facts

- Police received tips from two anonymous informants that Louis R. Edmunds was growing marijuana on his property.
- Officers obtained and executed a search warrant for a building on Edmunds’s property and seized marijuana plants and related items.
- The warrant affidavit did not state when the informants observed the alleged marijuana.
- The trial court found the affidavit failed to establish probable cause because it did not show the information was timely.
- Despite the defect, the trial court admitted the evidence after finding officers relied on the warrant in good faith and considered testimony outside the affidavit.
- Edmunds was convicted in a bench trial of multiple drug and conspiracy offenses based on the seized marijuana.

## Issues

1. Whether Article I, Section 8 of the Pennsylvania Constitution permits a “good faith” exception allowing admission of evidence seized under a warrant later found unsupported by probable cause.
2. Whether Pennsylvania’s warrant and suppression rules require the probable-cause determination to be confined to the written affidavit rather than supplemented by later oral testimony.

## Decision

- The Supreme Court of Pennsylvania reversed the Superior Court.
- The court held Pennsylvania does not recognize the federal “good faith” exception to the exclusionary rule under Article I, Section 8.
- Because the warrant lacked probable cause, the seized evidence had to be suppressed, and the convictions dependent on that evidence could not stand.
- The court adopted a structured approach for independent state constitutional analysis (commonly called the “Edmunds factors”).

## Legal Principles

- Article I, Section 8 may provide greater protection than the Fourth Amendment, even when the texts are similar; state courts must conduct an independent analysis before following federal precedent.
- In Pennsylvania, the exclusionary rule serves not only to deter police misconduct but also to protect privacy and preserve judicial integrity.
- A “good faith” exception that admits evidence from a warrant unsupported by probable cause is inconsistent with Article I, Section 8’s purposes and Pennsylvania’s strict probable-cause tradition.
- Pennsylvania policy favors confining probable-cause review to the four corners of the written affidavit in support of the warrant, rather than using later testimony to salvage an otherwise deficient warrant.
- The “Edmunds factors” for deciding whether to depart from federal constitutional doctrine are: (1) text, (2) history, (3) decisions from other states, and (4) policy considerations and unique state interests.

## Conclusion

Pennsylvania’s highest court held that Article I, Section 8 does not allow a Leon-style good-faith exception and requires suppression when a warrant is unsupported by probable cause, while also establishing a framework for independent interpretation of the state constitution.


Commonwealth v. Edmunds, 586 A.2d 887 (Pa. 1991)