Sanger

MEMORANDUM **

Martin Andrew Sanger appeals his conviction following his conditional guilty plea to one count of firearm possession by a felon, in violation of 18 U.S.C. §§ 922 (g)(1) and 924(e). We have jurisdiction under 28 U.S.C. § 1291 . We affirm.

Sanger contends that police lacked probable cause to arrest him because, at the time of his arrest, he was suspected to be a passenger in a vehicle that had been reported stolen. We review de novo whether probable cause supported a suspect’s warrantless arrest. United States v. Buckner, 179 F.3d 834, 837 (9th Cir.1999). Sanger’s contention fails. After reviewing the record, we conclude that, even assuming Sanger was arrested, the totality of the circumstances support a finding that Sanger’s relationship with the vehicle’s driver was more substantial than that of driver and passenger and that the officers had probable cause to believe Sanger was involved in criminal activity. See id. at 837-39 (concluding that passenger’s presence in a car of suspicious provenance loaded with commercial quantity of drugs can support an inference that the passenger was connected to criminal activity); cf. Rohde v. City of Roseburg, 137 F.3d 1142,…