United States v. Santana

In August 1974 undercover police officer Michael Gilletti of the Philadelphia narcotics squad set up a purchase of heroin from a woman named Patricia McCafferty. Officer Gilletti had purchased illegal drugs from McCafferty in the past, and when he approached her to set a time for his buy, McCafferty told him to meet her at a set location, and to bring $115 with him. After obtaining $110 in marked bills from his commanding officer, Gilletti met McCafferty and the pair drove to the home of Mom Santana, to purchase the heroin.

McCafferty took Gilletti's money and entered the house, pausing first to speak with a man named Alejandro (who became one of the respondents in this case), and emerged shortly thereafter bearing several envelopes containing heroin, which she handed over to Gilletti. At this point Gilletti identified himself as a police officer, placed McCafferty under arrest, informed her the police would be raiding Santana's house shortly, and asked her what had happened to the money he had given her. McCafferty informed him that she had given the money to Mom Santana, and Gilletti passed this information along to Sergeant Pruitt, who would lead the raid.

When Pruitt and his team arrived, they saw Santana standing in the doorway of her house with a brown paper bag in her hand. As the officers got out of their vehicles and approached Santana, she attempted to withdraw into her house, but was apprehended in the vestibule. As she tried to elude the officers, Santana dropped several "glazed paper packets" containing a "white powder" (subsequently identified as heroin). Alejandro picked up the packets and attempted to make off with them, but was apprehended before he could leave the premises. Santana was then ordered to empty her pockets, and was found to be in possession of $70 of the marked bills given to McCafferty by Gilletti.