D.Minn.: When the CI has apparent inside information, corroboration of innocent details can be enough

“Here, the caller provided descriptive information regarding both Defendant and the gun that he was holding, as well as predictive information indicating that Defendant would be found at the apartment because he was seen running back inside there. ‘The information was specific rather than generic and therefore unlikely available to someone without reliable insight into [Defendant’s] activities.’ … Also, some of the information provided by the caller was corroborated: the description of the Defendant matched Defendant’s appearance, Defendant was observed by police at the place where the caller stated he was, and the apartment building where the caller stated Defendant would be found matched the place where police had tracked the Defendant’s cell phone a few days prior.’ … ‘Even the corroboration of minor, innocent details’ can be enough to support a finding of probable cause.” United States v. Smith, 2021 U.S. Dist. LEXIS 252542 (D.Minn. Dec. 8, 2021).

A Pennsylvania inmate sues for transfer for safety. n.2: “Samuels’ cursory reference to the Fourth Amendment claim is unlikely a viable claim because ‘the Fourth Amendment right to privacy, to be free from unreasonable searches, is fundamentally inconsistent with incarceration.’ Doe v. Delie, 257 F.3d 309, 316 (3d Cir. 2001) (citing Hudson v. Palmer, 468 U.S. 517 (1984)).” Samuels v. FRM Superintendent, 2022 U.S. Dist. LEXIS 20216 (W.D.Pa. Feb. 3, 2022).*

This entry was posted in Informant hearsay. Bookmark the permalink.

Comments are closed.