Cited by

See Edwards, 451 U.S. at 482

11 investigation does not per se transform an investigatory detention into an arrest, nor does placing the suspect in the back of a squad car while the investigation proceeds.”

d 138, 149 (Minn. 2024) (per curiam) (anonymous); (describing a first-time citizen informer); McCloskey, d at 704 (informant); (confidential reliable informant).

“A search conducted without a warrant is unreasonable unless it satisfies ‘one of the well-delineated exceptions to the warrant requirement.’” State v. Barrow, 8 ().1 One well-delineated exception to the warrant requirement is an inventory search of an automobile that is being impounded by the government.

The mobile nature of vehicles can create situations in which “an immediate intrusion is necessary if police officers are to secure the illicit substance.” (quoting United States v. Ross, 456 U.S. 798, 806-07 (1982)).

10 “Generally, searches conducted outside of the judicial warrant process are per se unreasonable.”

(“The independent corroboration of even innocent details of an informant’s tip may support a finding of probable cause.”).

“Having a proven track record is one of the primary indicia of an informant’s veracity.”

“The probable cause necessary to support a warrantless search of a motor vehicle ‘must be based on objective facts that could justify the issuance of a warrant by a magistrate and not merely on the subjective good faith of the police officers.’” (quoting United States v. Ross, 456 U.S. 798, 808 (1982)).

d 128, 136 (Minn. 1999) (citing Terry v. Ohio , 392 U.S. 1, 22 (1968)).

(citing Terry v. Ohio, 392 U.S. 1, 22 (1968)).

The investigator testified that the CRI has provided reliable, verifiable information “dozens of times.” (holding that CRI was reliable because CRI “had given the police reliable information in the past”).

The CRI had a proven t rack record of reliability because they previously provided “names of individuals suspected to be involved in controlled substance crimes,” 8 which has “led to the seizure of controlled substances and multiple arrests for controlled substances in the past.” (“Having a proven track record is one of the primary indicia of an informant’s veracity.”).

d 128, 135 (Minn. 1999).

Further, “briefly handcuffing a suspect while the police sort out the scene of an investigation does not per 7 se transform an investigatory detention into an arrest.”

“Generally, searches conducted outside of the judicial warrant process are per se unreasonable.”

An officer who has a reasonable belief that the suspect is armed “is justified in proceeding cautiously with weapons ready.” (quotation omitted).

We note that in cases involving an informant, whether the warrant application “establish[es] probable cause to search depends on the totality of the circumstances of the particular case, including the credibility and veracity of the informant.” (emphasis added) (citing McCloskey, d at 703).

the court noted that officer testimony that a CRI has 7 given reliable information in the past is sufficient to establish the informant’s reliability without the need for specific details about that prior cooperation.

(citing Terry v. Ohio, 392 U.S. 1, 22 (1968)).

“To conduct a limited stop for investigatory purposes, a so- called Terry stop, the police must have reasonable articulable suspicion of criminal activity.” (citing Terry v. Ohio, 392 U.S. 1, 22 (1968)).

(citing Terry v. Ohio, 392 U.S. 1, 22 (1968)).

(quotation omitted); (stating that a court may consider “the credibility and veracity of the informant” in determining whether a CRI’s tip can establish probable cause to search).

The mobile nature of vehicles can create situations in which “an immediate intrusion is necessary if police officers are to secure the illicit substance.” (quoting Ross, 456 U.S. at 806-07).

(emphasis added) (quotation and citations omitted).

A search conducted without a warrant is unreasonable unless it satisfies “one of the well-delineated exceptions to the warrant requirement.”

Whether information provided by a confidential informant can establish probable cause “depends on the totality of the circumstances of the particular case, including the credibility and veracity of the informant.”

see also 2 Wayne R. LaFave, Search & Seizure § 3.3(a) ( 6th ed. 2004) (noting that informant’s credibility is often established because of the informant’s past performance).

(citing Terry v. Ohio, 392 U.S. 1, 22 (1968)); see also State 5 v. Diede, .

The supreme court has held that “briefly handcuffing a suspect while the police sort out the scene of an investigation does not per se transform an investigatory detention into an arrest, nor does placing the suspect in the back of a squad car while the investigation proceeds.”

rev. denied (Minn. July 25, 2000).

-04 (Minn. App. 2004) (), rev. denied (Minn. June 15, 2004).

Reasonable, articulable suspicion requires only that the investigation “was not the product of mere whim, caprice, or idle curiosity.” (quotation omitted).