Officers had probable cause for defendant’s stop based on officers’ listening to telephone calls between him and the CI. United States v. Santiago-Pagan, 2009 U.S. Dist. LEXIS 54202 (M.D. Pa. June 26, 2009).*
“[E]ducated deductions and inferences, taken along with the suspicious financial transactions and the strange living and employment conditions observed by the agents, lead the Court to find that the affidavits sufficiently link Zhu’s residence and business to the possible harboring and employment of undocumented aliens.” Thus, the ICE agent showed PC. United States v. Da Zhu, 2008 U.S. Dist. LEXIS 109086 (S.D. Ga. April 30, 2008).*
The fact that defendant’s car rental agreement had expired was cause to extend the stop to inquire of the rental company whether continued driving was permitted. Commonwealth v. Watts, 74 Mass. App. Ct. 514, 908 N.E.2d 788 (2009).*
Officers were looking for a vehicle involved in a robbery and had a description. An hour later, they saw a vehicle matching the description and stopped it. Individually, the factors were innocent, but, collectively, they gave cause for a stop. State v. Porter, 2009 Ohio 3112, 2009 Ohio App. LEXIS 2655 (4th Dist. May 26, 2009).*
The bus company’s employee opened the package shipped from Denver to Albuquerque, and reopening it was not unreasonable under Jacobsen. Indeed, this case is a lot like Jacobsen. State v. Rivera, 2008 NMCA 49, 207 P.3d 1171 (2009), on remand from State v. Rivera, 2008 NMSC 56, 144 N.M. 836, 192 P.3d 1213 (2008):
P14 In the present case, Agent Perry’s actions were based upon his belief that the package had already been opened by the Denver station employee. As discussed above, the Denver station employee notified the Bus Company’s Los Angeles office, which then contacted Agent Perry with information on a package with suspicious contents. The package was rewrapped and sent to Albuquerque per Agent Perry’s instructions, and, once in Albuquerque, it was opened under Agent Perry’s supervision. The facts are remarkably similar to those in Jacobsen, and, in following the reasoning established therein, we similarly hold that Agent Perry’s search and seizure of the package was not unreasonable because a privacy expectation in the privately opened package no longer existed. See id. at 111-12. Just as in Jacobsen, Defendant’s “privacy interest in the contents of the package had been largely compromised.” Id. at 121. Thus, when Agent Perry opened the package and observed the same bundles previously described to him, his actions were within the scope of the privacy violation already perpetrated by the Denver station employee. Even if Agent Perry cut open one of the bundles in Albuquerque, as Defendant alleges, he did not unreasonably expand upon the original breach of Defendant’s expectation of privacy. The knowledge Agent Perry gained from the Bus Company employee about the package, his experience with drugs and packaging of drugs, and his observations of the package and the bundles within would have supported his actions. Agent Perry’s investigation did not unreasonably expand the private search and was therefore not a violation of the Fourth Amendment.
“Because the objective circumstances confronted by defendant on the night in question suggested that plaintiffs’ home was being vandalized and that a missing teenage girl was in the house and in need of assistance, the search was reasonable under the Fourth Amendment exigent circumstances doctrine. We thus reverse the judgment of the district court and grant the defendant qualified immunity in this case.” Hunsberger v. Wood, 2009 U.S. App. LEXIS 13925 (4th Cir. June 29, 2009).*
