Commonwealth v. Sanchez

In August 1993, an agent from the federal Bureau of Alcohol, Tobacco, and Firearms (ATF) was investigating possible drug trafficking by observing a Federal Express location in Bakersfield, California. The agent saw what he believed to be a suspicious package being sent by California residents to Pennsylvania. After further inquiries heightened the agent’s suspicions, the agent arranged for a canine search of the package; the canine confirmed the presence of illegal drugs. The agent allowed the package to be shipped to Pennsylvania and informed the local police in Pennsylvania about the package. The local police obtained a search warrant for the package based on the information supplied by ATF. The search revealed that the package contained marijuana. The police then obtained a search warrant for the premises to which the package was meant to be delivered. That search uncovered evidence that Angel Sanchez and J. J. Briceno-Rodriguez (defendants) were engaged in drug-related crimes; Sanchez and Briceno-Rodriguez were charged with such crimes in Pennsylvania state court. Sanchez and Briceno-Rodriguez argued that the evidence obtained in the search of the premises should be suppressed because the search violated both the Fourth Amendment to the United States Constitution and the Pennsylvania Constitution. Per Sanchez and Briceno-Rodriguez, (1) Pennsylvania law applied to the California canine search because evidence law is procedural (not substantive) and Pennsylvania courts should apply Pennsylvania law to procedural issues and (2) the canine search was illegal under Pennsylvania law. The trial court granted Sanchez and Briceno-Rodriguez’s motion to suppress. The superior court reversed, holding that California law applied and that the canine search was legal under California law. Sanchez and Briceno-Rodriguez appealed.