PA: CI isn’t corroborated solely because he helped make another case

The CI led to another case, but the information here wasn’t corroborated and easily could have been. “We acknowledge that this is a close case. However, the police had every opportunity to pursue more substantial corroboration prior to preparing the affidavit of probable cause, but failed to do so. We simply do not believe that, without more, the CI’s reliability was established solely by the fact that he had provided a tip leading to one still-pending prosecution, the details of which were not included in the affidavit of probable cause.” The trial court acknowledged it was thin, and the court of appeals recognizes it’s close. [No mention of good faith exception.] Commonwealth v. Manuel, 2017 PA Super 94, 2017 Pa. Super. LEXIS 227 (April 7, 2017), § 16.05 .

Patrol officers have a duty to respond to 911 calls, and that leads to consensual encounters. Based on the totality, “Officers Henderson and Brown were justified in making such a stop and conducting a protective frisk for officer safety based on their reasonable suspicion that criminal activity was afoot.” The frisk produced a gun. United States v. Clark, 2017 U.S. Dist. LEXIS 51943 (E.D. Mo. March 1, 2017),* adopted, 2017 U.S. Dist. LEXIS 50902 (E.D. Mo. Apr. 4, 2017).*

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