People v. Robbins CA2/1

BACKGROUND

On May 27, 2014, the Los Angeles Police Department (LAPD) was conducting a “buy-bust” narcotics operation in Watts’s Nickerson Gardens housing projects. LAPD selected Nickerson Gardens, an area well-known for drugs and dominated by the Bounty Hunter Bloods gang, because it had received complaints that narcotics sales were occurring there. After observing patterns of foot traffic in the area and concluding narcotics sales were, in fact, likely occurring, LAPD equipped a nonconfidential informant (NCI) with an audio and video recorder and supplied her with a marked $10 bill to purchase narcotics. Defendant was in the area, sitting shirtless in a chair counting a large pile of money on his lap. The NCI approached defendant after another purchaser pointed her in his direction to obtain narcotics. After a brief conversation, the NCI tried handing defendant the marked $10 bill. Defendant would not take the bill, but nodded his head in the direction of two other individuals, Raymond Shipp and Latassha Cox, and

People v. Marsden (1970) 2 Cal.3d 118 (Marsden).

2 said, “over there.” The NCI walked in the indicated direction, placed the marked bill into Cox’s outstretched…