In the Interest of Y.W.-B., a Minor; In the Interest of N.W.-B., a Minor

Summary

The Pennsylvania Supreme Court held that child protective services must establish traditional probable cause under the Fourth Amendment and Article I, Section 8 of the Pennsylvania Constitution before a court can compel a home inspection, rejecting a "social worker exception." The Court found DHS failed to establish probable cause where an anonymous report of homelessness was refuted by the agency's own investigation and a single allegation of failing to feed a child during an eight-hour period lacked a nexus to the home or evidence of ongoing neglect. The Court reversed the order compelling the home visit, emphasizing that the sanctity of the home requires a firm probable cause showing before a state agency can compel entry.

Holdings

1. DHS did not establish probable cause. The evidence was insufficient: the anonymous report was uncorroborated, the homelessness allegation was rebutted, the failure to feed allegation had no nexus to the home, and the prior dependency history was stale.
2. The prior dependency history was stale and irrelevant because it was four years old and the conditions had been resolved. Mother's demeanor alone cannot support probable cause.

Questions Presented

1. Whether the Superior Court erred in creating a rule of law that violates Article I, Section 8 of the Pennsylvania Constitution and the Fourth Amendment of the United States Constitution by allowing a home inspection based on an anonymous GPS report without a showing of a link between the allegations and the home, and without a showing of particularity.

Disposition

reversed