S.D.Ala.: The known CI’s staying involved in the operation supported credibility because it was against penal interest

“It is unnecessary to identify the bare minimum required for an informant’s tip to support reasonable suspicion, because the circumstances of this case rise far above that threshold, and the question is not at all close. Laffitte did not receive his information from an anonymous, faceless tipster but from an informant with whom he had worked for several months and who had provided reliable information about criminal activity in the past. Nor did the informant slip into the shadows after providing the tip; instead, he or she remained actively engaged in the operation, exposing himself or herself to repercussions should the tip prove unfounded. Moreover, the informant both explained how he or she knew about the defendant’s illegal activity and provided an accurate prediction of the defendant’s future behavior.” United States v. Vanderlinde, 2015 U.S. Dist. LEXIS 142918 (S.D.Ala. Oct. 21, 2015).

Defendant’s stop was lawful, and he was hauling a large freezer. While a warning ticket was being prepared, a Spanish speaking officer arrived and also asked for consent. Defendant agree to both the English and Spanish versions, and the consent was valid. United States v. Triana, 2015 U.S. Dist. LEXIS 142802 (M.D.Ga. Oct. 21, 2015).*