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Com. v. Nace
Citations: 571 A.2d 1389; 524 Pa. 323; 1990 Pa. LEXIS 70
Court: Supreme Court of Pennsylvania; March 18, 1990; Pennsylvania; State Supreme Court
The Supreme Court of Pennsylvania reviewed the case of Commonwealth v. Nace to determine if the police exceeded the scope of a lawful inventory search when examining an address book taken from Appellant Sandy Michael Nace. The court referenced its previous rulings in Commonwealth v. Scott and South Dakota v. Opperman, which upheld the admissibility of evidence obtained during a warrantless inventory search as long as the search does not transition into a criminal investigation. On July 26, 1985, Nace and two associates were detained in connection with the murders of victims Sandra L. Wiker and Paul R. Conrad. During the inventory process, the police found an address book in Nace's wallet, which contained a phone number linked to victim Conrad. This evidence was later pivotal at trial, supported by witness testimony indicating Nace requested the victim's number. Despite Nace's argument that the search of his wallet was unnecessary since his identity and contact details were already known, the court maintained that the inventory search was routine and lawful, thereby validating the admissibility of the address book and its contents. Ultimately, Nace was convicted of two counts of second-degree murder and sentenced to two consecutive life terms. The court concluded that the address book's seizure was appropriate under the circumstances of the inventory search. The allegation challenges the conduct of police during an inventory search, asserting it exceeded the lawful limits set by established legal standards. Inventory searches, as a recognized exception to the Fourth Amendment's warrant requirement, are justified as part of routine procedures during arrest and booking, allowing police to search personal effects without a warrant. These searches aim to protect the defendant's property, shield police from theft claims, prevent hidden weapons, and verify the defendant's identity. The document references significant legal precedents, establishing that as long as searches align with police caretaking functions, they are constitutionally reasonable. In the case at hand, the appellant contends that the police unlawfully examined his wallet for evidence of guilt. However, the court maintains that inspecting the wallet's contents was a lawful part of the inventory process, necessary to account for valuables and prevent future disputes regarding the wallet's contents upon the appellant's release. The court concluded that no warrant was required for this action, affirming the trial's introduction of evidence found in the wallet. The dissenting opinion, authored by Chief Justice Nix and joined by Justice Zappala, criticizes the majority's view, arguing that the search was conducted with investigatory motives rather than pure caretaking. It suggests that recording a specific telephone number from the address book, which became critical evidence, indicates a lack of adherence to lawful inventory search principles. Nix asserts that the situation does not exemplify a legitimate caretaking search, emphasizing the necessity for a clear distinction from investigative motives.