U.S. v. Anglin

In prosecution on Hobbs Act robbery and firearm charges, Dist. Ct. did not err in denying defendant’s motion to suppress his arrest on ground that police lacked probable cause, where instant arrest was based on tip police received from informant about planned robbery under circumstances where tipster’s credibility had been untested at time of defendant’s arrest, and where police had been unable to corroborate allegations of criminal conduct until after defendant had been arrested on traffic stop. Police had probable cause to arrest defendant, where police had corroborated numerous details of planned robbery that had been supplied by tipster, which included facts that only someone close to defendant would have known. Moreover, tipster’s status as individual under federal sentence only enhanced his credibility, where tipster faced serious consequences if he had lied to officers, and defendant’s attempted flight during police attempt to make traffic stop was additional factor supporting finding of probable cause. Ct. further found that Hobbs Act robbery was “crime of violence” that would support defendant’s firearm conviction under section 924(c)(1)(A)(iii). Ct., though, ordered limited remand for reconsideration of terms of supervised release, where Dist. Ct. had improperly failed to orally pronounce each term of supervised release and had failed to give defendant meaningful opportunity to object to said conditions that had been included in pre-sentence report.