In the united stated District Court for the middle district of Pennsylvania
Paternoville Division

United states of america, ) No. 09 CR-1917 ) ) v. ) ) )
BOBBY LANE, ) ) Defendant )
___________________________________ )

Defendant’s trial brief in support of its motion to suppress evidence

Michael K. Cutter Cutter and Associates, P.A. 1000 Anystreet Rd. Jacksonville, FL 32202 (904)-555-555

Attorneys for Defendant Bobby Lane

QUESTION PRESENTED I. Whether the Court would erode the Fourth Amendment’s intent to protect citizens’ rights to be secure against unlawful arrest by admitting evidence when it was found on Defendant’s person subsequent to a warrantless arrest for which Defendant was wrongly suspected of being a Jewelry Store Burglar based on static details given by an anonymous caller and police observation that something “sparkly” was in Defendant’s van, further Defendant never “voluntarily” consented to the warrantless arrest, and most notably seizure for the arrest in question occurred inside the threshold of Defendant’s home?

Table of Contents Page
Question Presentedi.

Table of authoritiesiii.

Statement of the case1

summary of the argument2

Argument3

I. MR. BOBBY LANE’S FOURTH AMENDMENT RIGHTS WERE VIOLATED WHEN he was SIEZED INSIDE THE THRESHHOLD OF HIS HOME WITHOUT WARRANT, ABSENT PROBABLE CAUSE FOR THE JEWELRY BURGLARY, OR A CONCENT EXCEPTION. THEREFORE, THE COURT SHOULD GRANT THE MOTION TO SUPPRESS EVIDENCE3

A. Defendant Was Inside The Threshold Of