United States v. Rowe, No. 16-4102 (8th Cir. 2017)
Annotate this CaseProbable cause for the stop and search of a vehicle may be based on the collective knowledge of all law enforcement officers involved in the investigation and need not be based solely upon information within knowledge of the officer(s) on the scene if there is some degree of communication. The Eighth Circuit affirmed defendant's sentence and conviction for conspiracy to distribute cocaine. The court held that, given the collective knowledge of the investigating officers, including the corroborated confidential informant tips both previously and ongoing, the alert, and the request by officers for Trooper Thul to stop the identified vehicle, the stop itself was supported by probable cause. In this case, the collective knowledge of the investigating officers supported the traffic stop and detention of defendant, as well as his arrest. Finally, the district court did not err by denying a mitigating role reduction under USSG 3B1.2.
Court Description: Beam, Author, with Loken and Colloton, Circuit Judges] Criminal case - Criminal law and sentencing. While the district court did not err in relying on evidence adduced at a suppression hearing concerning his co-defendants held before defendant's initial appearance in the case, the evidence produced at defendant's subsequent suppression hearing established probable cause for the traffic stop; probable cause may be based on the collective knowledge of all of the law enforcement officers involved in the investigation and need not be based solely upon information known to the officer making the stop if there is some degree of communication among the officers; the district court did not err in denying defendant's request for a mitigating role reduction under Guidelines Sec. 3B1.2.
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