California, United States of America
The following excerpt is from People v. Espino, 202 Cal.Rptr.3d 354, 247 Cal.App.4th 746 (Cal. App. 2016):
did the civilian's observation of a furtive movement provide probable cause, as the movement itself lacked sufficient criminal connotation. (Gallik v. Superior Court (1971) 5 Cal.3d 855, 859, 97 Cal.Rptr. 693, 489 P.2d 573 [to constitute probable cause, a furtive gesture must be invested with guilty significance];
[247 Cal.App.4th 761]
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