Defendant isn’t entitled to a Franks hearing: “The addition of the omitted information to the search warrant application would not have detracted from the probable cause and may very well have strengthened the probable cause stated in the affidavit.” United States v. Mustelier, 2017 U.S. Dist. LEXIS 28784 (S.D. Fla. Feb. 16, 2017).
Boilerplate allegations of official custom or usage showing excessive force don’t survive a 12(b)(6) motion to dismiss. Marsh v. Long, 2017 U.S. Dist. LEXIS 30308 (N.D. Okla. March 3, 2017).*