## Facts

- A Pennsylvania state trooper stopped a vehicle after receiving information it had been involved in a drug transaction and observing a broken tail light.
- Richard Allen Johnson was a passenger; the trooper requested identification and ran Johnson’s name through an in-car system.
- The system reported an active arrest warrant; the trooper arrested Johnson and performed a search incident to arrest.
- The search yielded 37 packets of suspected heroin, two cell phones, and $1,674 in cash.
- After transport to the barracks, Johnson received Miranda warnings and made statements about drug dealing and, later, about being a user and the money being a tax refund.
- The trooper later learned the warrant was invalid because it had been served nine days earlier and should have been recalled.
- Johnson was charged with controlled substance offenses under Pennsylvania law.
- The trial court suppressed the physical evidence and statements under Article I, Section 8 of the Pennsylvania Constitution; the Superior Court affirmed.

## Issues

1. Whether evidence seized incident to an arrest based on an invalid arrest warrant must be suppressed under Article I, Section 8, even if the officer reasonably and in good faith believed the warrant was valid.

## Decision

- The Supreme Court of Pennsylvania affirmed the Superior Court’s order affirming suppression.
- The Court held the arrest was unlawful because the warrant was invalid, making the search incident to arrest unlawful.
- The Court declined to recognize a good-faith exception under Article I, Section 8 for reliance on erroneous warrant information.
- The physical evidence and Johnson’s post-arrest statements were suppressed.

## Legal Principles

- Article I, Section 8 of the Pennsylvania Constitution provides an exclusionary rule that does not include a Leon-style good-faith exception.
- Under Pennsylvania precedent, suppression serves not only deterrence but also the protection and vindication of privacy rights guaranteed by Article I, Section 8.
- Evidence obtained as a result of an arrest predicated on an invalid warrant is subject to suppression under Article I, Section 8, even when the arresting officer acted reasonably and in objective good faith.

## Conclusion

The Pennsylvania Supreme Court required suppression of evidence and statements obtained after an arrest based on an invalid warrant, reaffirming that Article I, Section 8 does not permit a good-faith exception for police reliance on erroneous warrant records.


Commonwealth v. Johnson, 86 A.3d 182 (Pa. 2014)