The Commonwealth asked the panel to overturn a suppression order, arguing officers lawfully searched a backpack found in a small motel room incident to an arrest and as part of a protective sweep. Attorney Charlie Marshall said the documentary record (including bodycam footage) supports an inference the backpack was accessible and within the grab area of those arrested.

The justices repeatedly pressed counsel for factual specificity: where in the room was the bag located, was it locked in a closet or safe, and whether the record permitted a reliable appellate finding that the bag was within reach of the arrestee or companions. Counsel conceded the record was sparse but argued the room was small and de facto accessibility supported the search; the bench observed that absence of foundational testimony about placement undercuts the Commonwealth’s burden for a warrantless search exception.

The panel also discussed distinctions between protective sweeps, Terry-type frisk authority, and searches incident to arrest, and whether motor-vehicle cases like Lucido translate to hotel-room entries, noting heightened privacy expectations in residences/hotel rooms. Defense counsel emphasized the trial judge’s factual findings and urged deference.

Why it matters: The court’s resolution will shape the limits of warrantless searches in confined residential settings and will clarify evidentiary burdens for law enforcement when justifying bag searches during arrests.

Result: Argument submitted to the panel.