Commonwealth v. Carroll (U)

The trial court did not err in suppressing evidence obtained following the defendant’s warrantless arrest, following Collins v. Virginia, 138 S. Ct. 1663 (2018).

Police had probable cause to arrest the defendant for felony eluding after he led them on a high-speed chase, but they encroached his curtilage and arrested him there without a warrant. Although they had probable cause, they weren’t faced with any exigency when they encountered him.

Affirmed. Senior Judge Haley dissented.

Commonwealth v. Carroll (U), No. 0975-18-4, Nov. 20, 2018. CAV (Malveaux) from Fairfax (Bernhard).



Categories: Court of Appeals of Virginia, Opinions, Unpublished

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