M.D.Pa.: Tracking data obtained by SW is not testimonial for Crawford purposes

Tracking data on defendant’s vehicle in a stalking investigation was not testimonial for Crawford purposes, and it comes in as a business record. United States v. Miah, 2021 U.S. Dist. LEXIS 224557 (M.D.Pa. Nov. 22, 2021).

A citizen complaint against law enforcement officers led to filing a false police report charge against the complainant. The district court did not err in granting summary judgment to a county sheriff’s office and officers on the arrestee’s Fourth Amendment false arrest claim because they relied on their good faith belief, after three separate levels of investigative review, that her actions provided probable cause for a charge. It also did not err in granting summary judgment to the sheriff’s office and officers on the arrestee’s Fourth Amendment excessive force claim. Body camera footage showed that the officers used the minimum force necessary. Peroli v. Huber, 2021 U.S. App. LEXIS 34515 (6th Cir. Nov. 19, 2021).*

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