D.Mass.: Part of CI’s criminal history wasn’t disclosed, but enough was; CI was corroborated, and there was PC

The affiant didn’t withhold enough of the CI’s criminal history to be misleading. Not all of it was disclosed, but enough was to show he was part of the criminal milieu. And even if the withholding was significant, there was still plenty of probable cause in the affidavit. The amount withholding doesn’t undermine it. And the CI was corroborated. United States v. Nuzzolilo, 2019 U.S. Dist. LEXIS 2184 (D. Mass. Jan. 7, 2019).*

The government used CSLI information in 2015 to connect defendant to a kidnapping that occurred months earlier. It was before Carpenter, and it was lawful at the time it was done. Motion to suppress CSLI denied. United States v. Alejandre, 2019 U.S. Dist. LEXIS 2048 (N.D. Ill. Jan. 7, 2019).*

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