E.D.Mich.: Drugs don’t have to be forensically tested after a controlled buy for there to be PC

The CI was corroborated and the totality gives probable cause. The fact that the drugs were not tested prior to the search warrant doesn’t undermine the probable cause or good faith because the officer could tell what it probably was. “Given the experience and corroboration of the affiant, the Court is not persuaded that probable cause did not exist because the substance purchased was not tested.” United States v. Green, 2018 U.S. Dist. LEXIS 179113 (E.D. Mich. Oct. 18, 2018).

The automobile exception applies to a stopped vehicle parked on the highway because it is still mobile [and subject to removal]. A dog alerted on the vehicle, the vehicle was seized, and a search warrant issued [even though not necessary under the Fourth Amendment]. State v. Bowen, 2018-Ohio-4220, 2018 Ohio App. LEXIS 4550 (5th Dist. Oct. 15, 2018).*