D.Mass.: A foreign law enforcement agency can be a CI, and these are the standards

“Given these facts, the Magistrate Judge reasonably relied on the foreign agency’s tip in concluding that probable cause existed to issue the search warrant because (1) ‘a tip from one federal law enforcement agency to another implies a degree of expertise and a shared purpose in stopping illegal activity,’ …; (2) the ‘working relationship’ between the United States and the FLA ‘bolsters the credibility of the information’ since the FLA’s ‘reputation can be assessed,’ and it ‘can be held responsible if its allegations turn out to be fabricated,’ …; and (3) ‘the source here was not only known to [federal law enforcement], but was also a repeat-player in the United States’ efforts’ at combatting child exploitation, …” United States v. Bateman, 2022 U.S. Dist. LEXIS 59570 (D.Mass. Mar. 31, 2022).

“The record establishes that Defendant abandoned his automobile after engaging law enforcement in a high speed chase. He fled on foot, leaving his car door open and his keys on the floorboard. Under these facts, Defendant retained no expectation of privacy in his vehicle and has no standing to assert a Fourth Amendment claim.” The vehicle was also subject to inventory. United States v. Pollard, 2022 U.S. Dist. LEXIS 59896 (D.S.C. Mar. 31, 2022).*

The smell of marijuana was probable cause. There were also multiple air fresheners, and that’s a tip off. The court of appeals doesn’t consider that the officer was inherently incredible on the dashcam. People v. Sims, 2022 IL App (2d) 200391, 2022 Ill. App. LEXIS 165 (Mar. 31, 2022).*