CA11: CI’s trip was not predictive but still [barely] enough to show reliability

The informant’s tip here was enough to show reliability, even though only readily observable facts were relied upon. “In this case, the tip did not predict Brown’s behavior; it only provided past or present information. As such, the tip is less reliable than if it had predicted Brown’s future actions. We do not suggest, however, that tips must always predict future behavior to be reliable. Prediction is but one indicator of reliability.” “Despite the tip’s lack of predictive power, the tip was reliable because the informant witnessed Brown selling drugs and the police corroborated presently observable facts, including Brown’s usual business practice [of selling heroin solely out of a backpack].” United States v. Brown, 2016 U.S. App. LEXIS 360 (11th Cir. Jan. 11, 2016).