CA6: Video of controlled buy corroborated CI; fact drugs wasn’t mentioned doesn’t mean no PC

The CI’s story is confirmed by the audio and video of the following controlled buy. Defendant’s claim that the money could have been paid for something else doesn’t undermine the probable cause. “Here, despite no explicit discussion of drugs, put in the context of the information already provided by the informant, there was a strong probability that Owens’s statements referred to a previous drug transaction with the informant. Moreover, this court defers greatly to a magistrate judge’s reading of the facts when issuing a warrant.” United States v. Owens, 2018 U.S. App. LEXIS 22108 (6th Cir. Aug. 9, 2018).

Hotel housekeeping discovered a working meth lab (such that it was) in one of their rooms, and they called the police who came and watched the room. Defendant was a passenger in a car that drove up to the room, and he didn’t have on a seat belt. The officer saw some furtive movements in the car. He approached the car to get the occupants out, and he could see a meth lab in the car. The observation did not violate the Fourth Amendment or state constitution. State v. Mathis, 2018 Tenn. Crim. App. LEXIS 595 (Aug. 9, 2018).*