PA: Warrant said “residence,” so it was not limited to garage, even though the PC was directed at it

The drug search warrant specified “the residence,” but the primary focus was the garage because that’s what the police knew. That did not mean, however, that only the garage could be searched. In the course of the drug investigation, police found evidence of murder and dismembering of the decedent. The warrant permitted the seizure of that which came into plain view. Commonwealth v. Chapman, 2016 Pa. LEXIS 550 (March 29, 2016).

A question to defendant about a gun in his truck was not barred by Miranda’s public safety exception (Quarles). Thus, defendant’s admission of the gun was probable cause for search for it. United States v. Milen, 2016 U.S. Dist. LEXIS 41364 (E.D.Tenn. March 3, 2016).