CA1: “Face-to-face” contact with CI by another officer was sufficient

“Although we have said that ‘face-to-face contact between the agent and informant’ and an agent’s opportunity to personally question him generally provides indicia of that informant’s reliability, see, e.g., Dixon, 787 F.3d at 59; Greenburg, 410 F.3d at 67, the absence of such an opportunity does not necessarily render the tip unreliable. Particularly here, where the tip was relayed from another officer who had such face-to-face contact with the informant. Maglio’s other challenges to the court’s factual findings, are similarly unconvincing. The court’s reading of the affidavit was reasonable, consistent with the information provided therein, and not clearly erroneous.” United States v. Maglio, 2021 U.S. App. LEXIS 38056 (1st Cir. Dec. 23, 2021)
http://media.ca1.uscourts.gov/pdf.opinions/20-1359P-01A.pdf

Defendant’s Franks challenge fails. Even if the omitted information had been included in the affidavit, the magistrate would have found probable cause. The 911 caller’s information was sufficiently corroborated to show probable cause. United States v. Smith, 2021 U.S. App. LEXIS 38038 (8th Cir. Dec. 23, 2021).*