Commonwealth of Pennsylvania, Appellant v. Curtis Jones, Appellee

Summary

The Supreme Court of Pennsylvania reversed the Superior Court's vacation of Curtis Jones's first-degree murder and robbery convictions, holding that the affidavit of probable cause — identifying the murdered student's last-known dormitory room, blocks from the shooting scene — gave the issuing authority a substantial basis, under the totality of the circumstances, to believe that evidence confirming the victim's identity and leads to his recent contacts would be found there. Rejecting the position that a warrant can never serve investigative ends, the Court relied on Pa.R.Crim.P. 201(3) and Warden v. Hayden to permit searches for 'mere evidence' of a known crime, and it sustained the bloodstained items as plain-view seizures made with a lawful right of access grounded in exigency. It further held the Superior Court erred in voiding the warrant over drugs and drug paraphernalia that were never seized, because suppression reaches only items actually taken without probable cause. Chief Justice Castille (joined by Justice Baer) concurred on the proper standard of review for magistrate probable-cause determinations, and Justice Todd (joined by Justice Saylor) concurred in the result while disputing that the Superior Court substituted its judgment for the police and finding the affidavit deficient as to the drug and weapon items.