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E.D.Pa.: Officer corroborated tip when they saw defendant with gun; hot pursuit into residence valid

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Officers got a man with a gun wearing a leather jacket with a hoodie on the street. Responding, defendant matched the description. When he saw a gun in defendant’s waistband, the report, even if anonymous, was completely corroborated. When defendant ran into a building, that was hot pursuit under Warden v. Hayden. United States v. Mallory, 2013 U.S. Dist. LEXIS 33532 (E.D. Pa. March 11, 2013). Where defendant’s own version of the events shows the search to be legal, a hearing isn’t required. United States v. Young, 2013 U.S. Dist. LEXIS 33496 (W.D. N.Y. January 16, 2013).* The state conceded standing, but the appeals court disagreed because it was a rental car that defendant had never been in. Even assuming there was a Fourth Amendment violation, the state showed inevitable discovery. State v. Horsley, 2013 Ohio 901, 2013 Ohio App. LEXIS 793 (4th Dist. February 8, 2013).*

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