“It is well-established that a ‘person may not be arrested, or must be released from arrest, if previously established probable cause has dissipated.’ United States v. Ortiz-Hernandez, 427 F.3d 567, 574 (9th Cir. 2005) (per curiam). ‘As a corollary … of the rule that the police may rely on the totality of facts available to them in establishing probable cause, they also may not disregard facts tending to dissipate probable cause.’ Id. (quoting Bigford v. Taylor, 834 F.2d 1213, 1218 (5th Cir. 1988)). A reasonable officer would know that participation in an ongoing seizure after any probable cause had dissipated violates the Fourth Amendment.” Detaining plaintiffs for five hours after probable cause dissipated was unreasonable. Nicholson v. City of L.A., 2019 U.S. App. LEXIS 24902 (9th Cir. Aug. 21, 2019).
The omissions from the search warrant affidavit weren’t material, and there was plenty for probable cause. United States v. Nichols, 2019 U.S. App. LEXIS 24793 (9th Cir. Aug. 20, 2019).*