S. Ct. Crim. No. 2012-0115

The prosecution's evidence was sufficient to support a conviction of the defendant for the crime of misprision of a felony in concealing an involuntary manslaughter, in which the victim was found in the defendant's home in circumstances suggesting a suicide. However, much of that evidence was obtained in violation of the defendant's Fourth Amendment rights. Once the defendant left his home, police investigators were required to obtain a search warrant to enter and search the premises, as the exigent circumstances that permitted their initial entry ceased. This violation of the defendant's Fourth Amendment rights cannot be deemed harmless since the People failed to meet its burden of showing that the error was harmless beyond a reasonable doubt. Accordingly, the defendant's conviction for misprision of a felony is reversed and vacated, and the matter is remanded for a new trial.