E.D.Mich.: IAC claim over search denied for lack of factual proffer

2255 petitioner’s IAC claim denied for generality and no factual basis: “Here, the petitioner has failed to develop any factual basis or legal argument on the performance element, beyond the naked assertion that his attorneys did not advance any arguments in the motion to suppress or motion for reconsideration based on the ‘fruit of the poisonous tree’ doctrine.” Utley v. United States, 2016 U.S. Dist. LEXIS 9995 (E.D.Mich. Jan. 28, 2016).

Pole camera surveillance of a house and defendant’s comings and goings led to reasonable suspicion for continuing his stop. United States v. Ortiz-Macias, 2016 U.S. Dist. LEXIS 10297 (E.D.Tex. Jan. 28, 2016).*

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