CA3: Parolee strip search in his own home was reasonable

Parole officers were properly granted summary judgment in a parolee’s claim that they unreasonably searched his property without cause. There was cause, there was no need for reasonable suspicion, and he established no material factual dispute about anything. Moreover, the strip search of defendant in his own home was reasonable under the circumstances because of his lesser expectation of privacy. Keating v. Pittston City, 2016 U.S. App. LEXIS 4485 (3d Cir. March 10, 2016).

The CI provided detailed information and had a positive track record, and that made him believable on cause for defendant’s stop for carrying drugs in the car. The tip was explicit on the drugs arriving at a post office and then being transported by car. The omission of a dog alert on the car from the affidavit for the search warrant on the car is not a Franks issue because it would have bolstered the finding of probable cause, not undermined it. Without it, however, there still was probable cause. United States v. Rowe, 2016 U.S. Dist. LEXIS 31141 (D.Minn. Feb. 11, 2016).

Defendant’s 2255 search claim was an effort to relitigate that which had already been decided. United States v. McCormick, 2016 U.S. Dist. LEXIS 30618 (E.D.Ky. March 10, 2016).*