Commonwealth v. Santiago, A., Aplt.

The "fruit of the poisonous tree" doctrine prohibits the admission of evidence at trial that was tainted by unconstitutional actions by law enforcement officials. Certain exceptions, however, exist to this doctrine. In this appeal by allowance, we consider whether a police officer's initial observations of a defendant at the scene of a crime, followed by a warrantless search of a cellular telephone left at the scene, which leads to the discovery of defendant's identity, taints the officer's subsequent in-court identification of the defendant. For the reasons set forth below, we find, under…