U.S. v. Sands

In prosecution on charge of felon in possession of firearm, Dist. Ct. did not err in denying defendant’s motion to quash his arrest and suppress gun seized from his vehicle, under circumstances where police officer received tip from reliable confidential informant that individual who matched defendant’s description was selling drugs from his vehicle at certain location, and where defendant was arrested at scene by another officer who had received report from first officer that he had witnessed defendant sell drugs from his car at said location to another individual. Instant arrest and subsequent search of defendant’s car was supported by probable cause based on informant’s tip and personal observations of first officer, and fact that arresting officer did not personally witness purported drug transaction did not require different result since collective knowledge doctrine applied. Moreover, subsequent search of defendant’s car was permissible where arresting officer could reasonably believe that vehicle contained contraband or other evidence of illegal activity.