D.Mass.: When defendant was arrested on a SW for premises for just him, a search incident of his bag while handcuffed would be unreasonable; but, he consented

Officers had a search warrant for premises (based on a warrant pinging his cell phone) to arrest defendant. The search incident of his bag at the time could not be justified by the search incident doctrine because he was handcuffed and in the presence of several officers. He did, however, consent to a search of the bag at the time of arrest. United States v. Goudreau, 2015 U.S. Dist. LEXIS 45279 (D. Mass. April 7, 2015).

Failure to challenge an OFAC blocking order of assets was not ineffective assistance of counsel where there was no authority holding that it would have succeeded. The fact later authority in another circuit came out the other way doesn’t really matter. Abdulqader v. United States, 2015 U.S. Dist. LEXIS 45080 (N.D.Tex. April 7, 2015).*

Defense counsel was not ineffective for not challenging the CI that said that defendant had a gun in the car because the CI was corroborated, and the challenge would have lost. Llera v. Comm’r of Corr., 2015 Conn. App. LEXIS 136 (April 14, 2015).*