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PA: Dead body in defendant's car + blood stains on his sidewalk + faint voice inside = exigent circumstances

By John Wesley Hall, Jr.

Finding a dead body in defendant’s vehicle was reason to go to defendant’s house. There the officers found blood on the sidewalk and on a broom on the sidewalk. Officers went to the door and heard a faint voice inside. There were exigent circumstances for the entry, and PC for the search warrant issued thereafter. [Note: This is not even a close call.] Commonwealth v. Galvin, 2009 Pa. LEXIS 2751 (December 28, 2009): Here, the affidavits of probable cause offered in support of the search warrant provided a description of the police observing Appellant driving the van at night without its headlights illuminated, the stopping of the van, the observation, in plain view, of Kolesnik's body, which was covered in a tarp which was wrapped with electrical wire, and on which there was blood...continue to full post

Full post as published by Fourth Amendment on January 03, 2010 (boomark / email).