D.Minn.: Crime Stoppers tip was sufficiently corroborated to show PC

Crime Stoppers tip was sufficiently corroborated to show probable cause [under Gates]. United States v. Gaston, 2021 U.S. Dist. LEXIS 65724 (D. Minn. Apr. 5, 2021):

Here, the information in the Crime Stoppers tip was independently corroborated by law enforcement and the tip correctly predicted Gaston’s travel across the country. Contrary to Gaston’s assertions, the information in the tip was not general but specific and detailed. The tip provided information on Gaston’s and Lindskog’s appearances, including Lindskog’s chipped front tooth, their birth dates, phone numbers, address, and Gaston’s criminal history. All of this detailed and specific information was corroborated by law enforcement with one minor discrepancy—Lindskog’s birthdate was off by one year. This minor discrepancy is inconsequential in light of all the other accurate information and does not undermine the reliability of the tip. See United States v. Amaya, 52 F.3d 172, 175 (8th Cir. 1995) (holding that slight discrepancies in information provided by informants was inconsequential in light of the totality of the circumstances).

The tip accurately predicted defendant’s travel itinerary and his method of travel, stating that he started in Vegas, stopped in Arizona, and was traveling back to Minnesota in a one-way rental vehicle. These predictions were corroborated by law enforcement through Gaston’s social media post, rental car records, and GPS tracking information. The fact that the tipster’s predictions of innocent behavior were accurate increased the likelihood that their prediction that Gaston was illegally trafficking drugs was also accurate. See Brown, 49 F.3d at 1349. Therefore, the tip supported probable cause to believe that the rental vehicle contained contraband or other evidence of a crime before the vehicle was stopped.