S.D.N.Y.: Database information linking def to a car linked to a crime can be PC

Database information linking defendant to a car linked to a crime can be probable cause. United States v. White, 2021 U.S. Dist. LEXIS 80608 (S.D. N.Y. Apr. 27, 2021):

The warrant application states that surveillance video captured footage of a vehicle involved in a robbery. (Warrant Application at 8, ¶ 10d.) Based on the video footage, which captured the physical characteristics and Pennsylvania license plate of the vehicle, law enforcement were able to locate the vehicle in “Department of Motor Vehicle databases.” (Id. at ¶ 10e.) The databases, along with the officer’s investigation, revealed that the vehicle, at the time of the offense, was registered to White’s wife. (Id.) Further, White is “affiliated” with the vehicle in “law enforcement databases.” (Id. at ¶ 11.) Probable cause was thus derived from multiple databases confirming White’s affiliation with the vehicle, and his wife’s ownership of it. This is far from a case where “the government relies solely on a computer database. . . .” Gonzalez, 975 F.3d at 819. The magistrate was entitled to grant the warrant on the basis of this probable cause.