CA1: Drug sale led to knock-and-talk and plain view of buy money

A drug sale occurred out of defendant’s house where a marked $20 bill was passed outside, the defendant went into the house and returned with drugs. Officers then did a knock-and-talk and saw the $20 bill in plain view. Its seizure was proper. United States v. Paneto, 661 F.3d 709 (1st Cir. 2011).*

Officers had reasonable suspicion for stopping defendant’s vehicle ½ mile from the Canadian border when it was driving in a “looping pattern” on a cold and rainy day (which is their smuggling prime time). Two other vehicles had been stopped that night for driving the same without anybody getting ticketed or further detained, although defendant was suspected of driving both vehicles (which he later admitted) which smelled of damp marijuana but had none inside. United States v. Mayhew, 2011 U.S. Dist. LEXIS 134395 (D. Vt. November 21, 2011).*

The testimony of the NYPD officer that he stopped the defendant’s car because of a partially obscured license plate is belied by a photograph. His fellow officer in the car was found not credible because he refused to answer questions appropriately about allegations of his ticket fixing going to his credibility. United States v. Williams, 2011 U.S. Dist. LEXIS 134352 (S.D. N.Y. November 21, 2011).*