Judge Paul Engelmayer
Based on a coconspirator’s tip DEA agents arrested Martinez at the site of a previously arranged drug transaction. The DEA searched Martinez’s car, finding a kilogram of cocaine. Martinez made post-arrest statements about his involvement in drug trafficking. An indictment charged Martinez with distribution and possession with intent to distribute 500 grams or more of cocaine. Seeking suppression of the cocaine, as contrary to the Fourth Amendment, Martinez argued the tip to the DEA was insufficiently reliable to support a finding of probable cause for his arrest, so that the subsequent search of his vehicle was unlawful. He also asserted the DEA agents inadequately advised him of his Miranda rights. The court denied suppression. As to the cocaine, the court determined that because the coconspirator had been proved right about independently corroborated facts—the time and place of the meeting, and the car Martinez would be driving—it was reasonable for the DEA agents to conclude that he was likely right about other facts, including the claim that Martinez was coming to the meeting place to deliver drugs. Thus the coconspirator’s tip was sufficiently corroborated to support a finding of probable cause to arrest Martinez.
