D.N.M.: It’s not a Franks violation to fail to mention any deals with the CI; it’s assumed

“Second, as to Mr. Ramos-Castillo’s argument that Agent Godier omitted material information by failing to include law enforcement’s numerous promises to Mr. Salazar, the Court finds that the failure to explicitly include this information does not amount to material omission that would vitiate probable cause. … Furthermore, the Tenth Circuit has noted that judges issuing search warrants ‘often know, even without an explicit discussion of criminal history, that many confidential informants suffer from generally unsavory character and may only be assisting police to avoid prosecution for their own crimes.’” The CI was corroborated enough to show probable cause. United States v. Ramos-Castillo, 2019 U.S. Dist. LEXIS 165009 (D.N.M. Sept. 26, 2019).

There was probable cause for defendant’s stop and search based on collective knowledge of the police. United States v. Pardo, 2019 U.S. Dist. LEXIS 165016 (D. Me. Sept. 26, 2019).*

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