Motion to Invalidate Warrant and Suppress Evidence due to Insufficient Probable Cause Grounded in Unreliable Flock Data

This motion seeks to invalidate a warrant and suppress all resulting evidence where the warrant rests solely on Flock data. It explains that Flock’s machine-learning model generates conclusions based on a non-public AI model with an unknown error rate, is vulnerable to hallucinations, and is highly sensitive to weather, lighting, noise, and partial plate captures, with studies showing accuracy can fall to “near zero” under certain conditions (pp.1-6). Because Flock functions like an uncorroborated anonymous informant, the motion argues that Flock data cannot establish sufficient veracity for probable cause and lacks particularity (pp. 7-12). It further contends that omissions about Flock’s known flaws defeat the good-faith exception (pp. 12-15).