PA: Trial court’s deciding to suppress based on an argument not made by def was error

Trial court’s deciding to suppress based on an argument not made by defendant was error. Commonwealth v. Jones, 2018 PA Super 208, 2018 Pa. Super. LEXIS 815 (July 17, 2018).

Defendant argues in post-conviction proceedings against the trial court’s ruling on a motion to suppress. Then defendant pled to the charge. The claim was sort of described as an ineffective assistance of counsel claim, but not quite, at least as described. At any rate, defendant loses because defense counsel was well prepared and defendant pled. State v. Curtis, 2018-Ohio-2822, 2018 Ohio App. LEXIS 3041 (5th Dist. July 16, 2018).*

“Upon reviewing Agent Taylor’s affidavit, we find that it provided a clear nexus between appellant’s alleged drug trafficking and his hotel room, and thus contained sufficient evidence to support a probable cause finding justifying the issuance of the search warrant.” State v. Nelson, 2018-Ohio-2819, 2018 Ohio App. LEXIS 3039 (12th Dist. July 16, 2018).*