Western Union’s production of money transfer records was a classic third-party record situation where there was no reasonable expectation of privacy. United States v. Escobedo, 2019 U.S. Dist. LEXIS 208067 (D. Mont. Dec. 2, 2019).
Defendant’s inconsistent story about whether he owned the vehicle he was driving, didn’t know the name of the guy who he bought it from, and that there was a woman’s purse in the car and other factors on the totality added up to probable cause to believe he was driving a stolen car when it was searched by the officer. United States v. Kissell, 2019 U.S. Dist. LEXIS 207905 (D. Kan. Dec. 3, 2019).*
“Here, there was probable cause to arrest Mr. McConnell based on both the CI’s report that he sold her 1.7 grams of methamphetamine and the officers’ witnessing defendant stalking the CI and then being stalked by defendant themselves.” The CI was also shown to be reliable. United States v. McConnell, 2019 U.S. Dist. LEXIS 207954 (N.D. Ga. Oct. 21, 2019),* adopted, 2019 U.S. Dist. LEXIS 207515 (N.D. Ga. Nov. 26, 2019).*