Q: What are some key cases establishing joint operations between two agencies and independent actions, esp. during searches

A: Understanding how courts determine whether law enforcement agencies are acting jointly or independently during searches is crucial. A key case in this area is **United States v. Reed**, 15 F.3d 928 (9th Cir. 1994). In this case, the court considered whether multiple agencies were operating as a single entity or independently. The court looked at factors such as the level of coordination and communication between the agencies and the extent to which they shared investigative goals and information.

Another important case is **United States v. Mendenhall**, 446 U.S. 544 (1980). This case established that mere presence of multiple agencies at a search scene does not necessarily mean they are acting jointly. The court noted that if one agency is merely providing assistance without participating in the core investigative activities, it might still be acting independently.

Finally, **United States v. Ramirez**, 523 U.S. 65 (1998), highlights the need to examine the specific roles and actions of each agency involved. If an agency's involvement is limited to providing security or logistical support, and they are not engaged in the actual search or decision-making process, they are more likely to be seen as acting independently.

These cases demonstrate that courts look at the nature and extent of collaboration between agencies. Key factors include communication, shared objectives, and the specific roles played by each agency during the operation. Analyzing these aspects helps determine whether agencies are conducting a joint operation or acting independently.