CA1: With great detail, independently corroborated, CI’s story is more believable

Defendant made three challenges to the search warrant and affidavit for a grow operation. First, the CI provided probable cause by his detail, which was corroborated by recorded telephone calls. While some of the calls seemed innocent, they take on a different color compared to the CI’s information. Second, the warrant was not stale, despite the two month lapse from the last PC to the issuances of the warrant because it was for an ongoing grow operation that would likely be there. Third, the warrant was not general. “Courts have recognized that ‘officers executing a search warrant are ‘required to interpret it,’ and they are ‘not obliged to interpret it narrowly.’” Here, they knew they were looking for a grow operation. United States v. Tiem Trinh, 665 F.3d 1 (1st Cir. 2011):

Furthermore, authorities independently corroborated many of the CS’s details through intercepted phone conversations and general monitoring of the Trinhs. See United States v. Soule, 908 F.2d 1032, 1039 (1st Cir. 1990) (noting that police officers’ contemporaneous corroboration of the “material elements” of the CS’s information “lent substantial intrinsic verification to the informant’s veracity and basis of knowledge”). Thus, the fact that surveillance observed seemingly innocent van travels between Boston and Buffalo takes on a greater significance and supports the CS’s credibility when viewed in light of other corroborative evidence indicating incriminating activity. See Greenburg, 410 F.3d at 69 (providing that a surveillance agent’s “observation of seemingly innocent truck movement, which matched the informant’s prediction about such activity, helped establish a substantial reason to believe that the informant’s description of the entire scheme was accurate”).