D.Minn.: The affidavit for SW was somewhat conclusory, but the officer’s efforts to corrorobate the CI showed GF

Officers had probable cause for a Facebook tracking warrant to provide information of where he was when he posted about his travels south to acquire fentanyl for sale in Minnesota based on informant hearsay and his two pending drug cases. When he fled officers in St. Paul, he had a backpack with fentanyl in it. United States v. Resendiz, 2023 U.S. Dist. LEXIS 68357 (D. Minn. Mar. 1, 2023),* adopted, 2023 U.S. Dist. LEXIS 67124 (D. Minn. Apr. 17, 2023)*:

And while written in a somewhat conclusory-fashion, the supporting affidavit, when read as a whole, suggests Bowman undertook a good-faith investigation into the informant’s tip and Resendiz’s conduct. In light of that background investigation, along with a neutral judge’s probable cause determination, it was not entirely unreasonable for law enforcement to rely on the warrant, even where the underlying application was somewhat sloppy. See Proell, 485 F.3d at 431. None of the four limits to the good faith exception apply here.

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