VI: Anonymous tip given observing altercation was sufficient for stop when substantially corroborated at scene

The detailed anonymous tip here was sufficient to support a stop when it was substantially corroborated at the scene. The caller observed an altercation in real time and described the two vehicles involved. It was at the top of a hill and not in a denser urban area where it would be harder to figure out who was involved, and that’s significant. “When Detective Carr arrived, he did not observe a fight, but he observed the two vehicles as described in the report, a male and two females, and the male immediately walked towards him in a brisk manner. The description of the vehicles and the individuals aligning with what was reported gave Detective Carr reasonable suspicion to stop the vehicles from leaving the area to determine if there was a dispute.” It all adds up to reasonable suspicion. People v. Dolphin, 2022 V.I. SUPER 88U, 2022 V.I. LEXIS 77 (Oct. 17, 2022).

Non-citizen defendants were arrested in international waters and brought to Southern Florida for prosecution. The Fourth Amendment’s 48 hour rule in County of Riverside doesn’t apply to them. United States v. Trench, 2022 U.S. Dist. LEXIS 192347 (S.D. Fla. Oct. 17, 2022),* citing United States v. Cabezas-Montano, 949 F.3d 567, 593-94 (11th Cir. 2020).

Defendant challenged the probable cause for the search warrant for his cell phones but not the seizure warrant. The probable cause was the same, and it’s sufficient. United States v. Bailey, 2022 U.S. Dist. LEXIS 192462 (E.D.N.Y. Oct. 21, 2022).*

Officers had reasonable suspicion for defendant’s patdown under Terry because they suspected he was just involved in a shooting incident. United States v. Barnes, 2022 U.S. Dist. LEXIS 192505 (S.D.N.Y. Oct. 21, 2022).*

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