Over on FourthAmendment.com, John Wesley Hall cites an interesting opinion:
An officer’s internet search provided a substantial basis for finding probable cause to search defendant’s house for evidence of misrepresenting military service. Citations to the places where the information was be found elevated this above a mere anonymous tip. United States v. Tang, 2021 U.S. Dist. LEXIS 101743 (E.D. Cal. May 27, 2021):
[T]he Court finds the magistrate judge had “a substantial basis” for determining there was probable cause that Tang had misrepresented her military service on her visa application and that evidence of such service would be found in her apartment. See Gates, 462 U.S. at 239. Defendant, however, argues there was not probable cause, as the internet sources relied upon in the affidavit and translation tools used were not verified for accuracy. See Mot. at 4-9. To support her position, Defendant relies on precedent finding that allegations of an unknown informant are insufficient to support probable cause. Id. at 8. It is well established that information from an unverified, anonymous tip alone is not enough to demonstrate probable cause. See Gates, 462 U.S. at 239. Something else is required to indicate it is reliable. See id. at 232-35. But the Court is not persuaded that this situation, where a trained FBI agent relies on certain sources found on the internet, is akin to an unverified, anonymous tip.
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