E.D.Va.: Corroboration of publicly known facts provided by CI here was enough

“The only facts that were independently corroborated by Detective Duquette were: (1) that Dixon lived at the Home, and (2) that he had previously been incarcerated in federal prison for selling illegal drugs and had been released in 2010.” “Here, where there were sufficient facts to indicate that CS1 was a reliable informant and Detective Duquette provided at least some corroboration of CS1’s tip, the Magistrate had a substantial basis on which to issue the warrant. In the alternative, the warrant will be upheld under the good-faith exception.” [In other words, corroborating obvious public facts is all it takes?] United States v. Dixon, 2014 U.S. Dist. LEXIS 79016 (E.D. Va. June 9, 2014).*

The record of the drug dog’s reliability is sufficient for probable cause. Defendant’s argument is essentially the “strict evidentiary checklist” that Florida v. Harris rejected. People v. Litwhiler, 2014 IL App (3d) 120431, 2014 Ill. App. LEXIS 386 (June 9, 2014).*

Encounter in a city park at 1:30 am started out as consensual and quickly escalated into more justifying backup. United States v. Fields, 2014 U.S. Dist. LEXIS 79447 (D. Mass. June 11, 2014).*