W.D.Pa.: CI’s story was substantially corroborated to provide PC; controlled buys the clincher

The CI’s story was substantially corroborated to provide probable cause. “In this case, Frampton’s affidavit provides substantial information about the CI’s reliability, from which the issuing judge could have inferred probable cause. The affidavit recounted the reliability of the CI’s past contacts with law enforcement, which led to multiple convictions and seizures of drugs and money. The affidavit disclosed law enforcement efforts to corroborate independently the information provided by the CI about McKinnon, including a search of McKinnon’s criminal history, review of property ownership records, a photograph identification (discussed in more detail below), and surveillance of the locations. Most importantly, the police officers corroborated the CI’s information about McKinnon’s drug dealing by observing the CI engage in multiple controlled purchases of drugs from McKinnon. In sum, McKinnon’s contention that the evidence should be suppressed due to a failure to establish the credibility of the CI is without merit.” United States v. McKinnon, 2021 U.S. Dist. LEXIS 863 (W.D. Pa. Jan. 5, 2021).*