D.Del.: Passenger lacked standing to contest placement of GPS, aside from the fact it was before Jones

Defendant as a passenger lacked standing in the GPS placement on another’s vehicle before Jones, never even having to discuss Davis good faith. United States v. Cabrera, 2014 U.S. Dist. LEXIS 96288 (D. Del. July 16, 2014).*

Defendant’s overbreadth challenge against a warrant for drug evidence such as drugs, paraphernalia, “drug ledgers reflecting drug transactions, financial transactions, suppliers and customers; photographs and video tapes that depict individuals involved in cocaine violations; and, bank records,” if there was any connection to a drug operation. “The warrant at issue in this case is precisely the type of warrant that courts routinely uphold against overbreadth challenges.” United States v. Pray, 2014 U.S. Dist. LEXIS 96792 (W.D. N.Y. July 14, 2014).*

All the facts in this case in the officer’s interaction with the defendant indicated that he was probably operating under the influence, and that justified his stop. Defense counsel was not ineffective for not filing a motion to suppress that wouldn’t succeed. State v. Waters, 2014-Ohio-3109, 2014 Ohio App. LEXIS 3039 (4th Dist. July 10, 2014).*