“In conjunction with these [in the totality of] circumstances, Houser and Williams’ statements against their penal interest were sufficient to reasonably assure the magistrate that the information they provided was reliable.” While the fact defendant was dealing drugs from a motel would suggest the transient nature of the occurrence and support staleness, the quantity of drugs alleged to be there overcame that. United States v. Bennerson, 2019 U.S. Dist. LEXIS 172483 (E.D. Tenn. Oct. 4, 2019), adopting 2019 U.S. Dist. LEXIS 173101 (E.D. Tenn. Aug. 26, 2019).
There was probable cause to arrest street vendors for being too close to the curb in violation of NYC law, and the district court erred in granting summary judgment. Crescenzi v. City of New York, 2019 U.S. App. LEXIS 29670 (2d Cir. Oct. 3, 2019).*