PA appeals court tosses man’s conviction, ruling State College police ‘exceeded their authority’
A statewide appeals court tossed Tuesday the conviction of a man accused of driving under the influence of alcohol in State College, ruling that key evidence was obtained illegally when borough police entered his residence without a warrant.
The decision from the state Superior Court effectively suppressed all evidence in the case against Maxwell Edgin, Centre County District Attorney Bernie Cantorna acknowledged Tuesday.
“I appreciate that the Superior Court upheld the requirement that police need to get a warrant before going into someone’s house,” defense lawyer Jason Dunkle said Wednesday.
Edgin, 26, was turned away in 2018 from a downtown State College bar because he was too intoxicated. He then hopped into his 2015 Ford F-150 and began to make his way back to his residence in Ferguson Township.
His erratic driving through densely populated areas prompted several calls to 911 from other drivers, including one woman who said Edgin drove through a red light and nearly crashed into another vehicle.
Edgin stumbled out of the pickup truck after parking at his residence, entered a code into a garage door panel made his way inside. Several State College police officers arrived minutes later; Edgin did not respond when officers knocked on his door.
Three officers — concerned that Edgin was injured or in the midst of a medical emergency, according to an affidavit of probable cause — entered the home without a warrant. They found him asleep on the second floor.
Police awoke Edgin and questioned him before he was transported by ambulance to Mount Nittany Medical Center. His blood alcohol content was 0.264%. The legal threshold for DUI is 0.08%.
“Even if we assume that the officers had an objectively reasonable basis for believing that Appellant needed immediate assistance, once they ascertained his conditions and acted upon it by calling the EMS, their authority for a warrantless entry into the residence ceased. At that point, the officers were required to leave the premises,” state Superior Court Judge Victor Stabile wrote. “Instead, after removing Appellant from his residence, the officers proceeded to detain, mirandize, and interrogate Appellant. In doing so, however, they exceeded their authority.”
Edgin was found guilty in February 2020 of two misdemeanor counts of DUI and five summary traffic violations. His sentence of six months of intermediate punishment was vacated with the state Superior Court’s decision.