D.P.R.: 6-8 hour old information a fugitive was in a house was too old to be relied upon for entry into home; no exigency

“[T]he officers’ belief that the fugitive was hiding in a home in Trinidad’s neighborhood consists of — to our knowledge — an imprecise, uncorroborated tip from a confidential informant whose reliability this court ignores. In fact, officer Negron readily admitted that he did not see the fugitive actually enter Trinidad’s home, but only crossing the street towards it. In this context, we find that the officers could not have formed a reasonable belief that Ramon Ortiz was inside Trinidad’s home some six to eight hours after Negron claims he saw the fugitive in that vicinity.” Thus, what was seen and seized inside is suppressed. United States v. Trinidad-Rivera, 2015 U.S. Dist. LEXIS 123234 (D.P.R. September 14, 2015).

The trial court erred in granting defendant’s motion to suppress. He was a passenger in a car stopped by a PIT maneuver and ended up struggling with officers attempting to catch him. The officer’s efforts were constitutionally valid. State v. Quarterman, 2015 Ga. App. LEXIS 537 (September 15, 2015).*