Bogan v. German (7th Cir. 2019) 774 Fed. Appx. 297 (Unpub.)

Parolee was suspected of a home invasion shooting over a drug debt. A vehicle, parked on the street in front of his residence, was impounded. Parolee claimed the vehicle was not his. Parolee detained in cruiser while parole agents waited for PSD to arrive. During the wait time (over an hour) LE consulted with the prosecutor’s office regarding getting a search warrant for the vehicle as well as trying to obtain additional information on ownership. PSD alerted to vehicle. Evidence from the shooting along with controlled substances were found in the vehicle. Parolee complained that his apartment was searched prior to LE finding out that he was on parole. Court held that parole agent’s knowledge could be imputed to the other LE on scene. Parolee also complained of a prolonged detention for the PSD. Court held that LE had probable to detain parolee and parolee had waived his 4th Amendment rights due to his status as a parolee. Court also stated: “We do not want to discourage this sort of careful, attentive police work even if it appears it could or should have been moved more quickly.” Good language for LE.