CA7: Def seen on his way to a controlled buy was PC

There was probable cause for the search of defendant’s car stopped on the way to a controlled buy. United States v. Coates, 2023 U.S. App. LEXIS 6108 (7th Cir. Mar. 15, 2023).*

Unreasonable responses from defendant stopping at a salvage yard in the middle of the night when no one else was around, at a time when most thefts at places like that occur, was probable cause. United States v. Stokes, 2023 U.S. App. LEXIS 6103 (8th Cir. Mar. 15, 2023).*

Defendant’s Franks challenge fails. “Neither Defendant Uvino nor Persico points to any credible or probative evidence to dispute the allegations in the affidavits and instead make conclusory statements challenging the validity of the alleged misstatements.” The affidavit shows probable cause. United States v. Russo, 2023 U.S. Dist. LEXIS 41817 (E.D.N.Y. Mar. 13, 2023).*

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