D.Me.: CI’s prediction of future events enhanced veracity

There was probable cause for the search, and the CI’s veracity was enhanced by the CI’s prediction of future conduct. United States v. Stevenson, 2020 U.S. Dist. LEXIS 105420 (D. Me. June 17, 2020).

“While Mendoza-Ricardo argues that the purpose of his traffic stop was completed as soon as officers arrested his passenger, the record shows that a key purpose of the stop was to question Mendoza-Ricardo regarding his activities at the suspected stash house. Having one of the HSI agents responsible for that investigation question him was reasonably related to that purpose, and the delay of approximately fifteen minutes needed for this to happen was not unreasonable under the circumstances. Accordingly, the officers’ detention of Mendoza-Ricardo did not violate the Fourth Amendment, and so we affirm his conviction.” United States v. Mendoza-Ricardo, 2020 U.S. App. LEXIS 18941 (6th Cir. June 15, 2020).*