“We conclude that, contrary to Combs’ assertions, there is no evidence that Davis intentionally or recklessly omitted material information from the affidavit. In fact, Davis’s testimony at the suppression hearing shows that the facts not included in the affidavit would actually have strengthened probable cause rather than defeating it.” Therefore, there was probable cause. United States v. Combs, 2018 U.S. App. LEXIS 8970 (4th Cir. Apr. 10, 2018).
The CI was interrogated in chambers by the judge, and his story satisfied Aguilar-Spinelli. People v. Jackson, 2018 NY Slip Op 02505, 2018 N.Y. App. Div. LEXIS 2483 (3d Dept. Apr. 12, 2018).*