CA2: Eyewitness report and identification of ptf was probable cause for arrest

Eyewitness report and identification was probable cause for arrest, so summary judgment was proper for the officer. Tortora v. City of New York, 2020 U.S. App. LEXIS 8135 (2d Cir. Mar. 12, 2020).*

The court credits the officers’ testimony that they saw him throw what they thought could be a firearm back to the back seat, and one testified he heard it hit the floorboard. That justified a protective sweep of the car. United States v. Reed, 2020 U.S. Dist. LEXIS 43646 (E.D. Mich. Mar. 13, 2020).*

Defense counsel wasn’t ineffective for not raising the need for a search warrant for CSLI back in 2012-13. United States v. Shaw, 2020 U.S. Dist. LEXIS 43680 (D. Kan. Mar. 13, 2020).*

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