KS: Controlled delivery doesn’t have to be hand-to-hand; picking up package from porch and taking it inside is enough

Defendant didn’t raise probable cause from the triggering event in an anticipatory warrant, but the suppression judge did. He directed the parties to litigate and brief it, so the issue was properly before the court. The triggering condition was acceptance of the package. When the delivering officer knocked, nobody answered, and the package stated it could be left. It was, and officers watched. Later, defendant picked up the package and took it inside. An actual hand-to-hand delivery is not required for the triggering condition. State v. Mullen, 2015 Kan. App. LEXIS 33 (May 1, 2015).

The CI made a call to the defendant about him bringing drugs, and the CI reported this to the officer. The CI could be credited. United States v. Silva, 2015 U.S. Dist. LEXIS 57609 (N.D.W.Va. April 10, 2015).*

Statements from witnesses that defendant was known to possess a sawed off shotgun did not even have to be coupled with a surveillance video and whether it was defendant or not. There was still probable cause. United States v. Evans, 2015 U.S. Dist. LEXIS 57371 (D.Minn. May 1, 2015),* R&R 2015 U.S. Dist. LEXIS 58005 (D.Minn. March 25, 2015).*

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