Citizen informants are presumed reliable. Coupled with trash pulls and the informants’ reports of repeated short term stays at defendant’s house, there was probable cause. State v. Laverdure, 2019 ND 72, 2019 N.D. LEXIS 59 (Mar. 15, 2019).
Officers had probable cause from observation of defendant’s activities to search his truck under the automobile exception. United States v. Rios, 2019 U.S. Dist. LEXIS 41211 (D. Me. Mar. 14, 2019).*
Trial court’s order to reveal the CI’s identity is reversed as improvident. No showing of need. Hill v. City of New YorkHill v. City of New YorkHill v. City of New York, 2019 NY Slip Op 01839, 2019 N.Y. App. Div. LEXIS 1861 (1st Dept. Mar. 14, 2019).*