The 911 caller here was an identified security guard who passed on detailed information he’d received from a source. The detail made it reliable enough for reasonable suspicion. United States v. Valenzuela, 2021 U.S. Dist. LEXIS 50262 (D. Minn. Feb. 3, 2021), adopted, 2021 U.S. Dist. LEXIS 47377 (D. Minn. Mar. 15, 2021).
“Movant also complains about his counsel’s failure to file motions to suppress. He has not shown, however, that he had any valid Fourth Amendment claim, much less that the outcome of the case would have been different had any particular evidence been excluded. … A mere allegation of prejudice is not sufficient.” Gossett v. United States, 2021 U.S. Dist. LEXIS 50696 (N.D. Tex. Mar. 17, 2021).*
The defendant police officer’s minor and ministerial role in bringing the plaintiff student to officers who interrogated her was shielded by qualified immunity. Her motion to dismiss should have been granted for lack of a clearly established violation of the Fourth Amendment. L.G. v. Columbia Pub. Sch., 2021 U.S. App. LEXIS 7904 (8th Cir. Mar. 18, 2021).*