D.S.C.: CI not sufficiently corroborated for PC for a vehicle search

Defendant was stopped for an alleged window tint violation, but the officer also relied on information from a CI from days before the stop that he thought was probable cause. The government had a dog sniff during the stop, but it does not rely on that at all. On the CI’s information, the officer relied on screen shots of text messages, but there is nothing to show that the text messages were between the CI and defendant. As to any other possible corroboration of the CI, the court cannot find sufficient corroboration of the CI to show probable cause for the automobile exception. Suppression granted. United States v. Carter, 2018 U.S. Dist. LEXIS 217343 (D.S.C. Dec. 28, 2018).*

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