E.D.Mich.: Officers’ efforts to avoid towing vehicle on def’s arrest showed lack of pretext to search it

The government satisfied its burden in showing that the inventory of defendant’s car was reasonable and not for an investigative purpose. Important to that, they attempted to work with defendant to avoid towing the vehicle at all by getting a family member to retrieve it. United States v. Edwards, 2019 U.S. Dist. LEXIS 128206 (E.D. Mich. Aug. 1, 2019).*

The CI’s information was sufficiently corroborated to substantially reduce the risk that the CI was lying. There was also nexus between the probable cause and the vehicle to be searched. United States v. Velarde-Pavia, 2019 U.S. Dist. LEXIS 128443 (D. N.M. July 31, 2019).*

The GPS search warrant for defendant was based on probable cause. What he claims was missing doesn’t alter the analysis because the probable cause is satisfied [and relatively low]. Sweeney v. State, 2019 Md. App. LEXIS 631 (Aug. 1, 2019).*