CA6: CI’s past reliability supported reliability here

“Here, the totality of the circumstances reveals enough to get the Government over the goal line, though perhaps not with a lot of breathing room. First, O’Bryan was a known informant. That means that O’Bryan “would [have been] subject to prosecution for making a false report,” and thus that his statements are “entitled to far greater weight than those of an anonymous source.” … That is one factor in the Government’s favor-and a major distinction between this case and cases like J.L. (which Stokes cites, see Appellant’s Br. at 12; Reply Br. at 4) that instead featured anonymous tips.” Moreover, the CI had proved reliable in the past. United States v. Stokes, 2018 U.S. App. LEXIS 19442 (6th Cir. July 16, 2018).*

“The instant motion asks that the Court suppress 280 bags of heroin seized from Defendant Mr. Vaquiz’s person during a search incident to arrest on January 29, 2016. Mr. Vaquiz specifically argues that officers lacked probable cause to arrest him because they relied upon the unreliable and suspect information of informant, J.F. However, because the factual record demonstrates that J.F. proved her reliability on numerous occasions and that the information provided by her was often independently corroborated by the officers in this case, I disagree. My reasoning follows.” United States v. Vaquiz, 2018 U.S. Dist. LEXIS 115709 (M.D. Pa. July 12, 2018).*