Commonwealth of Pennsylvania v. Kaitlyn N. Wolfel

Summary

This is a dissenting opinion by Justice Dougherty of the Supreme Court of Pennsylvania in Commonwealth v. Wolfel. The dissent addresses whether the Commonwealth preserved its challenge to the suppression court’s reliance on Article I, Section 8 of the Pennsylvania Constitution and whether the federal good-faith exception to the exclusionary rule applies to blood-test evidence obtained after Birchfield v. North Dakota. Justice Dougherty would affirm the Superior Court and hold that the good-faith exception applied.

Holdings

1. The Commonwealth preserved its challenge by arguing in the Superior Court that Birchfield was based solely on the Fourth Amendment and that inserting Article I, Section 8 analysis into the case was unwarranted.
2. The Fourth Amendment's good-faith exception to the exclusionary rule should apply to the blood-test evidence because the trooper acted in good-faith reliance on the law and training then understood to govern the search.

Questions Presented

1. Whether the Commonwealth preserved its challenge to the suppression court's reliance on Article I, Section 8 of the Pennsylvania Constitution.
2. Whether the Fourth Amendment's good-faith exception to the exclusionary rule applies to the blood-test results obtained in reliance on then-existing law and police training.

Disposition

other