E.D.N.Y.: NYPD’s I-Card system when based on PC satisfies collective knowledge

NYPD issues what it calls an “I-Card” (“Activate Investigation Card”) which is supposed to be based on probable cause to believe a person committed a felony. With probable cause, the I-Card provides collective knowledge for an arrest. United States v. Esters, 2022 U.S. Dist. LEXIS 201804 (E.D.N.Y. Nov. 4, 2022):

n.4: I-Cards are “an internal NYPD form issued by an officer when there is a suspect, witness, or perpetrator to be investigated.” Johnson v. City of New York, No. 15-CV-1625, 2017 WL 1476139, at *2 (E.D.N.Y. Apr. 24, 2017) (Gold, M.J.). There are two types of I-Cards: a “probable cause” I-Card and a “suspect only” I-Card. United States v. Fleming, No. 18-CR-197, 2019 WL 486073, at *2 (E.D.N.Y. Feb. 6, 2019). “Probable cause [I-Cards] signal that there is probable cause for a person’s arrest, whereas suspect only [I-Cards] show that the subject … is a person of interest.” Id. The I-Card at issue here was of the “probable cause” type.

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