CA2: Def’s possession of multiple cell phones and drugs packaged for street sale created inference more in hotel room

The search of defendant’s person produced multiple cell phones and drugs packaged for street-level sale. There was a fair probability there would be more in his hotel room since drug dealers usually have a base of operations. United States v. Joyner, 2022 U.S. App. LEXIS 545 (2d Cir. Jan. 7, 2022).

The CI’s information was timely and based on personal observation of seeing a drug deal in defendant’s house. The CI had previously provided controlled buys for the police. His information was thus sufficiently reliable for probable cause. United States v. Bell, 2022 U.S. App. LEXIS 536 (6th Cir. Jan. 6, 2022).*

A statement suppressed in a criminal case because it was taken outside the officer’s territorial jurisdiction is not suppressed in a child custody matter. The court long ago held that suppression of seized evidence doesn’t apply in civil cases. Muscha v. Krolik, 2022 ND 4, 2022 N.D. LEXIS 15 (Jan. 6, 2022).*

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