DE: Name of owner of property in SW doesn’t need to be identified to be valid

Defense counsel was not ineffective for not challenging that defendant wasn’t named in the search warrant for his specifically described property. [Remember, search warrants are usually for specifically ID’d places, and naming the owner is almost never necessary. If the SW is for a person in a place, the person has to be named.] He also waived it by pleading guilty and getting the habitual allegation dropped taking him away from a mandatory life sentence, and that was a bargained for benefit in the plea. State v. Green, 2015 Del. Super. LEXIS 186 (April 8, 2015).*

Defense counsel wasn’t ineffective for not challenging a seizure of a T-shirt linked to defendant that was abandoned in the woods. No reasonable expectation of privacy there. [He really expects a search warrant for the woods?] State v. Bissoon, 2015 Del. Super. LEXIS 184 (March 23, 2015).*

The record supports the trial court’s conclusion that defendant consented to two officers coming up to his second floor apartment, and a knife was in plain view on the bed in the small apartment. People v. Poinvil, 2015 NY Slip Op 25102, 2015 N.Y. Misc. LEXIS 1077 (2d Dept. April 3, 2015).*