D.N.M.: Citizen informants saw shooting, and video surveillance caught image of def’s car at the time, and that was PC for arrest

Citizen informants saw a shooting from a vehicle and area video surveillance caught an image of defendant’s car. Police looked, and he was convicted felon. There was thus probable cause for defendant’s arrest. United States v. Cotto, 2019 U.S. Dist. LEXIS 35544 (D.N.M. Mar. 6, 2019).*

Even if commenting on defendant’s refusal to submit to a blood draw without a search warrant was constitutional error, it was harmless beyond a reasonable doubt based on all the evidence here. State v. Jeske, 2019 Ida. LEXIS 55 (Mar. 8, 2019).*

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