CA3: Postal inspector had RS to detain package for dog sniff

“The [postal] inspector had reasonable suspicion. [¶] The inspector acted reasonably. Five signs aroused his suspicion: First, the package was from Puerto Rico, a common source of illegal cocaine shipments. Second, the package was sent by Priority Mail, a common way to ship drugs. Third, according to the databases used by the Postal Service, the sender and addressee listed on the package matched no one living at their purported addresses. Fourth, the package was mailed from a zip code different from the one on its return address. And fifth, three other Priority Mail packages had been sent from Puerto Rico to that address. [¶] Each of these facts (except perhaps the third) would be too generic to support a reasonable suspicion on its own. But we cannot evaluate these four facts ‘in isolation.’ Arvizu, 534 U.S. at 274. A ‘series of acts[, each] perhaps innocent in itself, [can], taken together, … warrant[ ] further investigation.’ Id. [¶] Taken together, these facts justified the inspector’s suspicion. ….” United States v. Ramos, 2020 U.S. App. LEXIS 28379 (3d Cir. Sept. 8, 2020).

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