LA2: A host of RS: (1) no DL or paperwork on car; (2) suspicious travel plans; (3) extensive criminal history of driver and passenger; (4) not knowing passenger’s name

“As previously noted in [the first appeal of this case,] Tpr. Sharbono’s testimony provided the articulable facts that raised his suspicions of other illegal activity: (1) Manning had no driver’s license or paperwork for the vehicle he was driving; (2) upon questioning, Manning related a suspicious account regarding his travel; (3) a criminal background check revealed Manning’s extensive criminal history; (4) Manning did not know his passenger’s last name; and, (5) Manning’s passenger also had a criminal record.” That was reasonable suspicion. State v. Manning, 2017 La. App. LEXIS 1455 (La.App. 2 Cir. Aug. 9, 2017).*

The motion for new trial or acquittal is denied. One ground was suppression of evidence, and it had already been determined there was probable cause for the search before the four month trial, and the court hasn’t seen anything that changes the ruling. United States v. Chester, 2017 U.S. Dist. LEXIS 124914 (N.D. Ill. Aug. 8, 2017).*

The Playpen warrant is sustained. The R&R recommending granting the motion predates United States v. Horton, 2017 U.S. App. LEXIS 13333 (8th Cir. July 24, 2017), which upheld Playpen warrants. United States v. Carlson, 2017 U.S. Dist. LEXIS 124452 (D. Minn. Aug. 7, 2017).*

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