D.S.C.: Nexus shown simply by drug dealer going home after the sale

The affidavit here was short, but not “bare bones.” Also, nexus is shown because defendant left the drug deal and went home. United States v. Hooks, 2014 U.S. Dist. LEXIS 183573 (D.S.C. April 21, 2014).

2255 petitioner did not show that defense counsel was ineffective. After he pled he reviewed the discovery more, and claimed errors in the investigative file. “Lacey’s sparse factual allegations largely consist of him haphazardly pointing out various portions of Corporal Whittington’s Investigative Narrative and simply claiming ‘that’s not what happened,’ without putting forth a specific and consistent narrative to counter Corporal Whittington’s.” He doesn’t allege enough to show that there was anything close to a Fourth Amendment violation that defense counsel overlooked. Lacey v. United States, 2015 U.S. Dist. LEXIS 52240 (E.D. Ala. February 11, 2015).*

Defendant was lawfully stopped because there were warrants out for his arrest. First, the gun was seen in plain view. Second, his arrest led to an inventory of the car which produced drugs from the console. Third, the second gun was valid either by the automobile exception or inventory. United States v. Stinnett, 2015 U.S. Dist. LEXIS 52210 (W.D. Mo. January 29, 2015).*