PA: On PCR, def has to call the third-party consenter as a witness to attempt to show lack of consent

On post-conviction review, defendant didn’t call as a witness the person who consented to the entry to testify that she did so involuntarily. Therefore, he failed in his burden of proof. Defendant was properly subjected to a DV arrest, even though he claimed there was no evidence of injury within the last 2–3 days. Commonwealth v. Hawkins, 2020 PA Super 280, 2020 Pa. Super. LEXIS 967 (Dec. 10, 2020).

The officer’s running defendant’s LPN gave the officer probable cause to believe the vehicle was uninsured. He attempted to stop it but defendant fled, wrecking the car. Inventory after that was reasonable. People v. Coss, 2020 NY Slip Op 07431, 2020 N.Y. App. Div. LEXIS 7636 (3d Dept. Dec. 10, 2020).*

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