Alleged ambiguities in the affidavit for the search warrant didn’t show a Franks violation where there clearly was probable cause. United States v. Jenkins, 2020 U.S. Dist. LEXIS 69247 (E.D. Ky. Apr. 21, 2020).
A 911 call from a cell phone captures the number and makes the citizen informant identified and, thus, more reliable. Finding defendant passed out in the car also supported the officer’s actions under the community caretaking function. State v. Clark, 2020 Tenn. Crim. App. LEXIS 273 (Apr. 21, 2020).
Reasonable suspicion supported this 51 minute detention waiting for the nearest drug dog. United States v. Orozco-Rivas, 2020 U.S. App. LEXIS 12703 (10th Cir. Apr. 21, 2020).*