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Pennsylvania v. Labron
United States Supreme Court
518 U.S. 938 (1996)
Police officers in Philadelphia saw Edwin Labron (defendant) participating in multiple drug transactions. The police arrested Labron, searched the trunk of his car, and found cocaine. The Pennsylvania Supreme Court held that the evidence discovered in Labron’s car should be suppressed because the police did not obtain a warrant to search the car, in violation of the Fourth Amendment. Under Pennsylvania law, the court concluded, police could only conduct a warrantless search of a car if there was probable cause and exigent circumstances that justified such a search. In Labron’s case, the police had adequate time to obtain a warrant and were not justified in conducting a search without a warrant. In reaching its decision, the Pennsylvania Supreme Court analyzed relevant state caselaw, the federal constitution, and the state constitution. Several of the state-law cases that the court cited incorporated analyses from federal cases. Pennsylvania (plaintiff) appealed the Pennsylvania Supreme Court’s decision to the United States Supreme Court, arguing that the decision ran contrary to federal law. Labron challenged Pennsylvania’s appeal, asserting that the Pennsylvania Supreme Court’s decision rested on adequate and independent state grounds and, therefore, could not be reviewed by the United States Supreme Court.
Rule of Law
Holding and Reasoning (Per curiam)
Dissent (Stevens, J.)
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