D.Nev.: Lack of officer reports of facts for PC to arrest goes only to their credibility, but they still were

There was ample probable cause for defendants’ arrest and stopping their car to do it despite the lack of reports. That goes to credibility, and the court finds it wanting. United States v. Davis, 2020 U.S. Dist. LEXIS 105973 (D. Nev. June 16, 2020).

The officer here was routinely patrolling a hotel parking lot because the operator found needles in the lot and complained of drug deals going on. Defendant’s vehicle was parked on the lot and the officer came on to the lot and saw defendant’s vehicle with two in it. He parked the patrol car not blocking defendant’s vehicle and walked over to it. Attempting to talk to him was not a seizure. United States v. Watkins, 2020 U.S. App. LEXIS 18983 (4th Cir. June 17, 2020).*

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