D.Minn.: Collective knowledge doctrine doesn’t require affiant officer to independently corroborate

The affidavit for the search warrant here was adequate to show nexus and probable cause for a search. The reliance on other officers’ information didn’t require this officer to independently corroborate it. United States v. Velazquez, 2020 U.S. Dist. LEXIS 110600 (D. Minn. Apr. 27, 2020), adopted, 2020 U.S. Dist. LEXIS 105172 (D. Minn. June 15, 2020).

“No reasonable officer could have understood these facts and circumstances to constitute probable cause to believe that Mills and Chun had committed the crime of theft by deception or any other violation of New Jersey law. … Thus, Mills and Chun have alleged facts sufficient to establish a violation of their constitutional rights, that is, the right under the Fourth Amendment to be free from arrest without probable cause. Such right was clearly established at the time of plaintiffs’ arrest. … When the arrest of a person is undertaken without probable cause as under the facts presented here, the search of that person and seizure of his or her property incident to arrest also violates that person’s clearly established rights under the Fourth Amendment. … Accordingly, the complaint states viable claims that defendants violated plaintiffs’ clearly established rights to be free from unreasonable search and seizure under the Fourth Amendment. Defendants are not entitled to qualified immunity.” Mills v. Golden Nugget Atl. City, LLC, 2020 U.S. Dist. LEXIS 110912 (D. N.J. June 24, 2020).*