E.D.Mich.: Where parole search required RS, anonymous tip consistent with other violation information was enough

A parole search under Michigan law only requires reasonable suspicion. An anonymous tip in the past has been held not enough. Here, however, the anonymous telephone tip was consistent with some of defendant’s parole violations, so here it’s enough. United States v. Noel, 2015 U.S. Dist. LEXIS 28067 (E.D. Mich. March 9, 2015).

Defendant accused of rape and gross sexual imposition on three boys. Two caught herpes. The search warrant for his blood alleged that he had been treated for herpes symptoms in custody and that was allegedly false. Whether it is or not doesn’t matter because omitting that paragraph from the affidavit still leaves probable cause to believe he was the transmission source. State v. Richardson, 2015-Ohio-824, 2015 Ohio App. LEXIS 795 (12th Dist. March 9, 2015).*

A probation search for a meth lab was justified. One of the tips was anonymous, but others weren’t and he preconsented to the search. State v. Vaughn, 2015-Ohio-828, 2015 Ohio App. LEXIS 794 (12th Dist. March 9, 2015).*