Why Did Evidence in Luigi Mangione’s (UnitedHealthcare CEO Murder) Trial Get Suppressed?

Overview

Following the high-profile homicide of UnitedHealthcare CEO Brian Thompson in New York in December 2024, defendant Luigi Mangioni was indicted of second degree murder. A few days after the alleged crime, local police found Mr. Mangione in a McDonald’s in Altoona, Pennsylvania. Both a search incident to arrest (SITA) and inventory were performed of his backpack. New York law applied to determine the evidentiary and suppression issues in the State murder case.

The evidence found in Mr. Mangione’s backpack during the SITA at McDonald’s was suppressed, where it was searched outside the handcuffed defendant’s reach. No exigent circumstances suggested he could gain access to destroy evidence or obtain a weapon. The Court rejected the argument that a “safety search” was necessary to ensure the backpack contained no bombs. This rationale was described as inconsistent where the search (1) was conducted near McDonald’s employees and customers; and (2) extended to small items unlikely to contain explosives, such as a wallet.

Items discovered in the backpack’s compartment opened for the first time at the station, during the inventory search, were not suppressed where Altoona Police Department protocol was followed. A red notebook, removed from the backpack at McDonald’s, was not excluded because it was not opened until the inventory search.

Initial Police Encounter with Mr. Mangione

On December 4, 2024, United Healthcare CEO Brian Thompson was fatally shot in Manhattan, New York. On December 9, Luigi Mangione was found in Altoona, Pennsylvania after McDonald’s employees called 911 to report a customer resembling the suspect. Local police arrived to see Mr. Mangione sitting in the restaurant with a laptop in front of him, and a backpack by his feet. When asked for identification, he produced a driver’s license discovered to be fake. Officers moved his laptop and backpack to a table around 9 feet away, and the defendant’s person was frisked. When asked if he had any weapons just prior to a second pat-down, he confessed to having a pocket knife. Mr. Mangione was handcuffed, and police put the knife on the table alongside the backpack and laptop. He was arrested for forgery and tampering based on the fake ID, in violation of Pennsylvania law.

Officers then searched Mr. Mangione’s backpack on a McDonald’s table, unzipping the main compartment and removing:

• A red notebook, kept closed.
• A waterproof bag holding a cell phone, passport, and wallet. The wallet and passport were opened and inspected.
• A pair of underwear, which police unrolled and discovered concealed a loaded magazine.
• A cardboard sleeve, which police used a knife to open, revealing a computer data chip.

After arriving at the Altoona Police station, officers collected Mr. Mangione’s clothing, including a USB drive hanging on a necklace he wore. Officers continued searching the backpack and opened a compartment for the first time, revealing a loaded handgun. Police then applied for a search warrant for the items in the backpack, which was issued by a Pennsylvania State judge.

New York Law Applied to Evidentiary and Suppression Issues in the State Law Murder Case

The Supreme Court of New York held that, as the forum state, its law applied to decide evidentiary and suppression issues in the State murder case. The Court held that Altoona officers’ reliance on PA law in good faith was immaterial, as this was not the rule to determine which state’s law applied.

SITA of the Backpack was Improper Where It was Outside the Defendant’s Grabbable Reach and No Exigent Circumstances Existed

For SITAs, New York State courts impose “spatial and temporal limitations to ensure that the search is ‘not significantly divorced in time or place from the arrest.’” Warrantless search of closed containers, even within an arrestee’s grabbable area, additionally requires exigent circumstances, namely officer safety or “protection of evidence from destruction or concealment.”

The backpack, placed on a McDonald’s table, was not within Mr. Mangione’s “immediate control or ‘grabbable reach’ at the time of the arrest or search,” where he was handcuffed around 9 feet away. The backpack was in “exclusive control of the police,” and no exigency was demonstrated. The Court rejected the argument that safety concerns necessitated searching to ensure the backpack contained no explosives. Described as inconsistent with this justification, the search (1) was conducted near McDonald’s employees and customers; and (2) included areas too small to hold a bomb, such as inside the wallet.

Conclusion

Although Mr. Mangione was arrested by Altoona police in Pennsylvania, New York law applied to decide evidentiary and suppression issues in the State murder case. To search closed containers incident to arrest, New York courts require (1) that the bag is within the arrestee’s grabbable area; and (2) exigent circumstances. The SITA of Mr. Mangione’s backpack was improper because it “was within the exclusive control of the police” where the defendant was handcuffed around 9 feet away. Evidence discovered during the McDonald’s search (including the phone, magazine, wallet, passport, and computer chip) was inadmissible, while the items found in the compartment opened for the first time at the station were not suppressed. The red notebook, removed from the backpack at McDonald’s, was not suppressed, as officers had not yet opened its pages.

Altoona police subsequently obtaining a search warrant did not circumvent the exclusionary rule, as the warrant application “relied partly on the evidence itself recovered from the backpack” during the SITA. Evidence discovered in a backpack compartment, opened for the first time at the station, was not suppressed because the inventory search complied with Altoona Police Department procedures.

References

1. People v. Mangione, Slip Op. 25213, Ind. No. 75657-24 (NY Sup. Ct. 09/16/2025) (dismissing first degree murder charges but upholding the indictment count of second degree murder (intentional) under NY Penal Law § 125.25 (1)).
2. “New York has a ‘paramount interest’ in the application of its law . . . suppression issues, procedural issues and evidentiary issues are governed by the law of the forum state.” People v. Mangione, Ind. No. 75657-24 at 9 (N.Y. Sup. Ct. 05/18/2026) (suppression order).
3. “Even a bag within the immediate control or ‘grabbable area’ of the suspect at the time of his arrest may not be subject to a warrantless search incident to arrest unless the circumstances ‘support a reasonable belief that the suspect may gain possession of a weapon or be able to destroy evidence located in the bag.’” Id. at 10.
4. “This initial inventory sufficiently complied with Altoona procedure to be a valid inventory search.” People v. Mangione, Ind. No. 75657-24 at 13 (N.Y. Sup. Ct. 05/18/2026) (suppression order).
5. “The red notebook will not be suppressed, as the officers did not open or search it at the McDonald’s.” Id. at 12 n.6.
6. “Suppression issues, including those arising out of a defendant’s constitutional rights, are generally governed by the law of the forum, and ‘New York has a paramount interest in the application of its laws to this case.’” People v. Espinal, 161 AD 3d 556, 557 (NY App. Div., 1st Dept. 2018).
7. Moreover, “New York does not have a good faith exception to the exclusionary rule.” People v. Bigelow, 66 N.Y. 2d 417, 422 (1985).
8. “Even a bag within the immediate control or ‘grabbable area’ of the suspect at the time of his arrest may not be subject to a warrantless search incident to arrest unless the circumstances ‘support a reasonable belief that the suspect may gain possession of a weapon or be able to destroy evidence located in the bag.’” People v. Jimenez, 22 N.Y. 3d 717, 722 (N.Y. App. 2014).
9. While this Article summarizes the suppression issues in the State murder case, the defendant’s motion to suppress was denied in the federal murder case. United States v. Mangione, 25-CR-00176 (U.S. Dist. Ct. S.D. N.Y. 01/30/2025) (denying motion to suppress).
10. To search closed containers incident to arrest, “the People bear the burden of ‘demonstrating the presence of exigent circumstances.’” People v. Jimenez, 22 N.Y. 3d 717, 722 (N.Y. App. 2014).
11. “[T]here was no possibility at the time of the search that the defendant might retrieve a gun from the backpack, and thus no exigency.” People v. Mangione, Ind. No. 75657-24 at 11 (N.Y. Sup. Ct. 05/18/2026) (suppression order).
12. “[T]he independent source doctrine does not apply, and to apply it under these circumstances would improperly vitiate the warrant requirement.” Id. at 14.