\u201cAlthough we have said that \u2018face-to-face contact between the agent and informant\u2019 and an agent’s opportunity to personally question him generally provides indicia of that informant’s reliability, see, e.g., Dixon, 787 F.3d at 59; Greenburg, 410 F.3d at 67, the absence of such an opportunity does not necessarily render the tip unreliable. Particularly here, where the tip was relayed from another officer who had such face-to-face contact with the informant. Maglio’s other challenges to the court’s factual findings, are similarly unconvincing. The court’s reading of the affidavit was reasonable, consistent with the information provided therein, and not clearly erroneous.\u201d United States v. Maglio, 2021 U.S. App. LEXIS 38056 (1st Cir. Dec. 23, 2021)
http:\/\/media.ca1.uscourts.gov\/pdf.opinions\/20-1359P-01A.pdf<\/p>\n\n\n\n
Defendant\u2019s Franks challenge fails. Even if the omitted information had been included in the affidavit, the magistrate would have found probable cause. The 911 caller\u2019s information was sufficiently corroborated to show probable cause. United States v. Smith<\/a>, 2021 U.S. App. LEXIS 38038 (8th Cir. Dec. 23, 2021).*<\/p>\n","protected":false},"excerpt":{"rendered":" \u201cAlthough we have said that \u2018face-to-face contact between the agent and informant\u2019 and an agent’s opportunity to personally question him generally provides indicia of that informant’s reliability, see, e.g., Dixon, 787 F.3d at 59; Greenburg, 410 F.3d at 67, the … Continue reading