Potential hand-to-hand drug deal in a car was reasonable suspicion for a stop. It’s what these officers were always looking for. [It may have ultimately had an innocent explanation, but it looked like it to them.] State v. Dunlap, 2018-Ohio-3658, 2018 Ohio App. LEXIS 3954 (9th Dist. Sep. 12, 2018).
“Moreover, false statements by an informant, whether they are purposeful or made in error, are insufficient to warrant a Franks hearing when there has been no showing that the statements were included intentionally or recklessly by the affiant.” The mistake as to defendant’s height (5’5″ v. 5’10”) and nationality (Jamaican v. Guyanese) wasn’t material to the finding of probable cause.
United States v. Cabrera, 2018 U.S. Dist. LEXIS 154808 (W.D. N.Y. Aug. 8, 2018),* adopted, 2018 U.S. Dist. LEXIS 154365 (W.D. N.Y. Sept. 10, 2018).*