Commonwealth v. Ryles

I agree with the majority that the suppression court erred in suppressing the physical evidence obtained pursuant to the second search warrant. I believe, however, that the suppression court properly suppressed Ryles’ inculpatory statement because it was obtained in violation of the Davenport rule.1

Our Supreme Court adopted the following rule in Davenport: “If the accused is not arraigned within six hours of arrest, any statement obtained after arrest but before arraignment shall not be admissible at trial.” 471 Pa. at 286, 370 A.2d at 306. In a footnote immediately following that statement,…