CA6: CI’s PC doesn’t have to be decided because there was good faith

The district court erred in finding no probable cause on information from defendant’s CI and no good faith exception. The CI was stopped one day out of jail driving a stolen motorbike that he said came from defendant. “In the end, though, we need not decide the probable-cause question because the good-faith exception applies. In considering the exception, the district court misapplied the good-faith standard. Although it correctly stated that a bare-bones affidavit is not simply one that lacks probable cause, the district court focused solely on whether the affidavit lacked probable cause and offered almost no analysis specific to the good-faith exception.” United States v. Houghton, 2021 U.S. App. LEXIS 19856 (6th Cir. July 1, 2021).*

Questions to the driver about travel plans didn’t unreasonably extend the stop because defendant himself was extending the stop looking for paperwork. In due course, reasonable suspicion developed. United States v. Callison, 2021 U.S. App. LEXIS 19771 (8th Cir. July 2, 2021).*