CA8: Car seizure for overtinting and inventory were reasonable

Defendant’s car was permissibly seized for overtinting, and the subsequent search was reasonable as inventory. United States v. Perez, 2022 U.S. App. LEXIS 8697 (8th Cir. Apr. 1, 2022).*

“Even assuming arguendo that Thrasher could make a substantial preliminary showing that the warrant affidavit knowingly or recklessly misrepresented the CI’s criminal history, the CI’s record of cooperation with law enforcement, or Thrasher’s criminal history, the inaccuracies Thrasher identifies are not material. The warrant affidavit made clear the CI’s significant criminal record, including a conviction for a crime of dishonesty. Many of the alleged inaccuracies regarding the CI’s record are minor or unproven allegations. Thrasher’s criminal history was not central to the warrant affidavit’s probable cause showing, and the warrant affidavit’s description does not materially alter the overall picture that Thrasher himself had a significant criminal history.” United States v. Thrasher, 2022 U.S. App. LEXIS 8686 (9th Cir. Mar. 31, 2022).*

Defendant’s credibility claim on voluntariness of consent to signing a consent form is rejected on appeal. United States v. Gonzalez, 2022 U.S. App. LEXIS 8688 (9th Cir. Mar. 31, 2022).*

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