United States v. Neal, 3:20-cr-00132

On Feb. 12, 2020, San Francisco officers arrested Tanlisia Neal outside her home at the intersection of 16th and Mission Streets for allegedly violating a no‑loiter order.
Officer Dudley (or his partner) had searched the police database four times in the two months before the arrest; each search showed a notation that Neal was subject to a no‑loiter order valid through Dec. 6, 2022.
Two of those database entries also noted Neal was “standing” or “loitering” at 16th and Mission; the last search occurred Feb. 8, 2020 (four days before the arrest).
Neal moved to suppress, arguing the arrest lacked probable cause and that the database was unreliable (the order was actually a pretrial order that terminated with the state case and had become legally invalid in May 2020).
The government argued officers reasonably relied on the database and that the entries provided probable cause to arrest for willful violation of the no‑loiter order.
The court concluded the database entries provided reasonable grounds for probable cause and denied Neal’s motion to suppress despite isolated database inaccuracies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless arrest violated the Fourth Amendment because officers lacked probable cause and unreasonably relied on an inaccurate database	Neal: arrest lacked probable cause; database errors show it was unreliable; arrest was based on suspicion/look, not violation of order	Government: database showed a valid no‑loiter order and recent notes of loitering; officers reasonably relied on that information to form probable cause	Denied suppression. Court held officers had probable cause and reasonably relied on the database despite isolated inaccuracies

District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (probable cause supports warrantless arrests for trespass/illegal presence)
Gonzalez v. United States Immigration & Customs Enforcement, 975 F.3d 788 (9th Cir. 2020) (reliance on government databases can be reasonable absent evidence of systemic errors)
Herring v. United States, 555 U.S. 135 (2009) (isolated negligence in maintaining records does not automatically require suppression)
Cornu‑Labat v. Merred, [citation="580 F. App'x 557"] (9th Cir. 2014) (upholding arrests based on database notations in similar contexts)