CA6: Assuming a lack of PC, the warrant was not bare bones and the GFE saves the search

Even assuming that the search warrant in this case was invalid for lack of probable cause, it was not so lacking of probable cause or “bare bones” that good faith did not support the search anyway. It was reasonable to infer that the seized trash bag came from defendant’s house because it was the only one around at the end of a dead end street, and the marijuana clippings in the trash bag were fresh and indicated that a grow operation was ongoing. United States v. Silvey, 393 Fed. Appx. 301 (6th Cir. 2010).*

The USDJ rejects the USMJ’s denial of defendant’s suppression motion because there was not justification for stopping defendant’s minivan for objects hanging from the mirror in violation of Michigan law. The officer was really acting on a tip from the DEA anyway. United States v. Adams, 2010 U.S. Dist. LEXIS 89745 (E.D. Mich. August 31, 2010).*

The CI’s information in this case was sufficient to find reasonable suspicion as the facts unfolded and corroboration was made. United States v. Vargas, 2010 U.S. Dist. LEXIS 89999 (D. Utah August 30, 2010).*

When a park ranger sees a traffic offense occurring as the defendant is leaving the park, it is not a violation of the Fourth Amendment for the officer to stop the defendant outside the park, and, thus, outside of the officer’s jurisdiction under Virginia v. Moore. United States v. Snow, 2010 U.S. Dist. LEXIS 89521 (D. Mass. August 5, 2010).*