In United States v. Mancilla-Ibarra, No. 17-13663
(Jan. 15, 2020) (William Pryor, Jill Pryor, Robreno), the Court affirmed
the defendant's drug conviction and sentence.
First, the Court upheld the denial of a suppression motion,
finding that probable cause supported the defendant's arrest based on
information provided by an informant.
The Court found that, under the totality of the circumstances of that
case, the informant's tip was shown to be veritable, reliable, and corroborated.
Second, the Court upheld the refusal to apply a two-level
reduction under the safety-valve provision in 2D1.1(b)(17). At issue was whether the defendant satisfied
the fifth criteria for truthfully disclosing all information about the offense. To show that the defendant failed to do so,
the government relied on testimony by an agent with only second-hand
information who had no personal knowledge about the defendant's interview. That equivocal and uncorroborated account was
not sufficiently reliable. However, the
defendant bore the burden to prove that he disclosed all truthful information,
and the record undermined his assertion that he made only two drug deliveries.
