NC: Informant doesn’t need “track record” to be creditable

The informant doesn’t need a “track record” to be credited as a source of information. State v. Vandergrift, 2026 N.C. App. LEXIS 202 (Mar. 18, 2026).

Police responded to a stolen ATM report and found defendant near an ATM in a shopping cart covered with a tarp. He matched the description they received. He had a ski mask on his head but it was hot. He reached for his waistband and tossed what officers believed was a gun in his car, locking it with the key fob. He was evasive in answering questions. This was reasonable suspicion. United States v. Pennycooke, 2026 U.S. App. LEXIS 7906 (3d Cir. Mar. 18, 2026).*

“The undisputed evidence in this case shows that Marr actively resisted arrest. When the officers first attempted to handcuff him, he prevented them from cuffing his right hand by pulling it away from their grasp. Then, after the officers wrestled him to the ground, he did not comply with their commands to stop moving and instead struggled and thrashed about. Such actions, this court has repeatedly held, permit officers to use force without violating clearly established law.” Est. of Marr v. City of Glasgow, 2026 U.S. App. LEXIS 7908 (6th Cir. Mar. 16, 2026).*

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