PA Court Reverses Marijuana Convictions Over Unreliable Search Warrant

Posted in Fourth Amendment on July 18, 2025

In a pivotal ruling for Pennsylvania criminal defense law, the Superior Court of Pennsylvania reversed the drug convictions of two York County men—Charles and Timothy Manuel—after finding that the search warrant used to enter their home lacked sufficient probable cause. This en banc decision underscores the importance of police corroboration when relying on tips from confidential informants (CIs).

Background of the Case

A confidential informant told  a York Area Regional Police officer that he had recently seen marijuana plants and drug packaging materials inside the Manuels’ residence. Based solely on this information—and minimal corroboration confirming the residence’s ownership—the officer obtained a search warrant.

Police executed the warrant and discovered marijuana plants, paraphernalia, and cash. The Manuels were charged with Possession with Intent to Deliver (PWID) under 35 P.S. § 780-113(a)(30). They later filed a joint motion to suppress the evidence, arguing that the search warrant was based on an uncorroborated and unreliable tip.

The Court’s Analysis – Reliability of CI’s Information

The court’s majority opinion focused on the lack of independent corroboration of the CI’s information. When seeking a search warrant, the police must provide information to the judge that there is probable cause to believe that evidence will be found in a particular location. This requires the police to give the judge information about the ‘veracity’ and ‘basis of knowledge’ of persons supplying hearsay information, meaning the police must provide information about why the CI should be believed. Has the CI provided accurate information in the past? How often? Was the cooperation recent? Did the information lead to convictions? Why does the CI know how to identify marijuana? Were the police able to verify or confirm any statements from the CI?

In this case, the CI had only previously supplied information that led to one arrest—not a conviction. The police did not conduct any controlled drug buys, surveillance, or trash pulls to verify the CI’s claims. Instead, they merely confirmed the residents’ names through PennDOT records. Basically, the police had no reason to believe the CI’s statements.

The court ruled that this minimal effort fell short of the standard for establishing probable cause. The affidavit failed to show the CI’s reliability and lacked adequate corroboration of criminal activity. As a result, the search warrant was invalid, and the evidence obtained under it should have been suppressed.

Legal Takeaway: Informant Tips Require Verification

This case highlights a critical legal principle: anonymous or confidential tips—especially from informants without a proven track record—cannot justify a search warrant unless they are independently corroborated. The court reaffirmed that probable cause requires more than a mere suspicion or unverified tip.

For criminal defense attorneys, this decision is a valuable precedent in challenging the sufficiency of search warrant affidavits. It demonstrates that courts will not rubber-stamp warrant applications based solely on thin or unverified CI information.

Why This Matters for Defendants in Pennsylvania

If you are charged with a drug offense in Pennsylvania and the evidence was obtained through a search warrant, your defense attorney should closely scrutinize the underlying affidavit. If the police relied on a questionable or unverified informant, your Fourth Amendment rights may have been violated, and the evidence could be suppressed.

Attorney obtained the suppression of cocaine evidence in a PWID case by challenging the probable cause in a search warrant for the client’s vehicle.

Consult an Experienced State College Criminal Defense Attorney

At JD Law, we routinely defend clients in State College and across Central Pennsylvania against drug charges. We closely examine every step law enforcement takes—from the initial tip to the warrant application. If your rights were violated, we fight to get the evidence thrown out and the charges dismissed.

For a free case review, contact JD Law by email or leave a message at (814) 689-9139. Email is the preferred method of communication, as phone calls are directed to voicemail due to the high volume of spam and unsolicited calls.