IA: Multiple hand-to-hand transactions over time was RS

Reasonable suspicion came here from an officer “witnessing what he believed to be a hand-to-hand drug transaction,” and there were “other facts that supported the conclusion they had reasonable suspicion of criminal activity. First, Girsch saw Baker acting suspiciously near 702 Ricker Street just two weeks prior to Baker’s arrest. Second, an anonymous caller reported that Baker had just returned to town with a large shipment of marijuana and that there was a large quantity of marijuana at the Ricker Street house. After receiving the tip, the investigators conducted surveillance of 702 Ricker Street, during which time they saw Baker leave the residence and then engage in what Isley believed to be a hand-to-hand drug transaction. While these circumstances alone may not rise to the level of reasonable suspicion, we consider the ‘totality of the circumstances.’” And it is. The anonymous tip alone was nothing, but it fit a pattern. State v. Baker, 2019 Iowa Sup. LEXIS 27 (Mar. 29, 2019).*

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