Pennsylvania v. Enimpah (majority)
Annotate this CaseAppellee Andrew Enimpah was a passenger in a car stopped by police; he was asked to step out of the vehicle, and when he did, a plastic bag fell from his lap. The driver consented to a search of the car and police seized the bag, which contained cocaine. All occupants denied knowledge of the bag, but appellee was charged. He moved to suppress, challenging the constitutionality of the detention that led to the search. At the suppression hearing, the prosecutor refused to offer evidence until appellee met the "threshold" of appellee offering proof of his reasonable expectation of privacy in the area where the plastic bag was found. After much debate, the trial court informed the prosecutor it would be obliged to grant the motion if she failed to present any evidence. The prosecutor maintained her position, stating, “If I’m wrong[,] the [a]ppellate courts will tell me that[;] then I will respect that decision.” The trial court suppressed the evidence; the Superior Court affirmed. The Supreme Court affirmed that decision and reiterated that which should be clear: "In all cases, the burden of production is [] upon the Commonwealth."
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