S.Ct. at 288). “[P]robable cause is a fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.” Illinois v. Gates, 462 U.S. 213, 232, 103 S.Ct. 2317, 2329, 76 L.Ed.2d 527 (1983). It “ ‘must be seen and weighed not in terms of library analysis by scholars, but as understood by those versed in the field of law enforcement.’ ” Texas v. Brown, 460 U.S. 730, 742, 103 S.Ct. 1535, 1543, 75 L.Ed.2d 502 (1983) (quoting United States v. Cortez, 449 U.S. 411, 418, 101 S.Ct. 690, 695, 66 L.Ed.2d 621 (1981)). Furthermore, a suspect’s actions that suggest “a consciousness of wrongdoing” can contribute to a finding of probable cause. See United States v. Vasquez, 638 F.2d 507, 521-22 (2d Cir.1980) (<HOLDING>), cert. denied, 454 U.S. 847, 102 S.Ct. 165, 70
holding that a defendant who had borrowed a car for a limited period of time had no legitimate expectation of privacy in the cars locked trunk where it was the very person from whom he had borrowed the car who first called the police after he failed to return the car holding that an arrest to retrieve car keys where ownership of the car was in dispute was not supported by probable cause holding that there was probable cause for arrest where officers knew defendants had recently been with suspected drug dealer officers saw defendants car being maneuvered so as to indicate that surveillance had been detected and when officers approached car defendant attempted to place package under car and then pulled the package back inside the car and closed and locked the car door holding that the driver of a car who had permission to use the car had standing to challenge its search holding that search of car was not incident to arrest where arrestee had exited and locked car before he was approached by officer and then arrested