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Commonwealth v. Hakim Johnson 2009 PA Super 41 (3/11/2009)

Topic: Suppression of Evidence – Exigency Exception to the Warrant Requirement

Summary: Where a police officer is attempting to determine the identity of a crime victim who is not suspected of committing a crime, exigent circumstances exist and a warrantless search will be justified.

Illustration: Hakim Johnson was shot in the mouth and brought to the hospital. While in the hospital, a police officer searched his clothes to find out his identity. The officer recovered drugs, paraphernalia, and a quantity of money. Since the officer was not investigating Johnson for a crime and was trying to determine his identity, the search is not prohibited by the Fourth Amendment.