DC: Tracking def off his WMATA fair card was like Knotts and reasonable

Police use of information off of defendant’s WMATA fare card first to find him to arrest him for a robbery on a train and then to place him on a train at the time of the robbery was reasonable. This is not at all like Carpenter and is more like the beeper in Knotts tracking him in a public place. Kelly v. United States, 2022 D.C. App. LEXIS 297 (Sep. 1, 2022).

No warrant is needed to forensically test DNA that was abandoned. McCurley v. State, 2022 Tex. App. LEXIS 6665 (Tex. App. – Ft. Worth Aug. 31, 2022).

The affidavit for warrant did not violate Franks. The witnesses gave a description that generally fit defendant, despite some contradictions. They also unequivocally identified him from a surveillance video. State v. Brown, 2022 S.C. App. LEXIS 103 (Aug. 31, 2022).*

There was probable cause for plaintiff’s arrest, so the officers prevail on summary judgment. Jackson v. Cowan, 2022 U.S. App. LEXIS 24736 (11th Cir. Sep. 1, 2022).*

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