M.D.Pa.: Conduct shown in affidavit was “protracted” and it wasn’t stale

The search warrant wasn’t stale because the conduct under investigation was “protracted.” “Williams’ piecemeal approach to the facts of the affidavit fails to acknowledge that probable cause is a holistic, totality-of-the-circumstances assessment. … The age of some of the historical information provided by Trooper Panchik4Link to the text of the note does not diminish the relevance of two completed controlled buys and a third controlled buy event, which led to a lawful arrest of Williams with three ounces of cocaine on her person. … Trooper Panchik’s first paragraph describing his investigation into Williams’ notes that five different confidential sources provided information in 2012, claiming Williams ran “a large-scale cocaine (powder and crack cocaine) distribution network in Harrisburg City.” … Subsequent pages describe multiple CIs who confirmed these claims in 2016, 2017, and 2018. … His affidavit describes a years-long investigation into ‘protracted and ongoing’ drug trafficking, meaning the age of any particular fact loses its importance. …” The CI was also properly supported. United States v. Williams, 2020 U.S. Dist. LEXIS 243471 (M.D.Pa. Dec. 29, 2020).

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