PA Court Reverses Suppression of Drug Evidence

Posted in Fourth Amendment on July 20, 2025

In Commonwealth v. Bentley, 1253 MDA 2024, the Pennsylvania Superior Court reversed the Lycoming County trial court’s decision to suppress evidence in a drug trafficking case. The ruling strengthens law enforcement’s ability to obtain search warrants based on tips from confidential informants and reinforces how courts should apply the “probable cause” standard.

Controlled Buy Leads to Drug Charges

The case began in Lycoming County when the Narcotics Enforcement Unit (NEU) arranged a controlled buy using a confidential informant (CI). The CI contacted Bentley and, within 20 minutes, purchased crack cocaine from him while officers observed. After the sale, Bentley told the CI he was retrieving “two more bags of crack cocaine” and would return immediately. Bentley then drove off.

Police stopped Bentley near a storage facility and found him with the marked buy money, an access card, and keys for a nearby storage unit. The CI confirmed Bentley used that storage unit and had moved items there the previous day. Using this information, police obtained a search warrant for the storage unit, where they recovered crack cocaine, fentanyl, MDMA pills, and a handgun with an obliterated serial number.

Trial Court Suppresses Evidence from Storage Unit

Bentley filed a motion to suppress evidence, arguing the warrant lacked probable cause. The Lycoming County judge agreed, finding the affidavit of probable cause accompanying the application for a search warrant didn’t sufficiently link the unit to drug activity and suggested officers should have waited for more concrete evidence before executing the search. The judge ruled that the search warrant was invalid, so the search violated Bentley’s 4th Amendment rights. The judge granted the suppression of all evidence. The DA’s Office filed an appeal to the Superior Court.

Superior Court: Police Had Probable Cause for Storage Unit Search

On appeal, the Superior Court reversed, holding that the magistrate had a substantial basis to issue the search warrant. The Court emphasized that probable cause requires only a “fair probability”, not proof beyond a reasonable doubt, that evidence will be found at a location.

The Superior Court found that several facts supported probable cause:

The trial judge was criticized for expecting a higher burden of proof and for second-guessing investigative tactics. The Court made it clear: search warrant affidavits must be judged by a commonsense, practical standard, and issuing authorities deserve deference when reviewing probable cause.

Impact on Pennsylvania Criminal Defense

This ruling is significant for anyone facing drug trafficking charges in Pennsylvania. It shows that courts may uphold search warrants based on corroborated CI tips and circumstantial evidence. But it must be emphasized that the poilce in this case were able to corroborate some of the information from the CI, and they actually observed some of the criminal activity. The Superior Court recently issued a decision granting suppression of evidence when the police did not corroborate information from the CI.

For defense attorneys, it emphasizes the importance of challenging search warrant affidavits based strictly on what’s within the “four corners” of the document. If you’re charged with a drug crime in Pennsylvania or believe police obtained evidence illegally, it’s critical to speak with a criminal defense lawyer who understands the nuances of search and seizure law.

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