The entry into defendant’s house on probable cause but without an arrest warrant was unreasonable. The officers claimed exigency from the fact they announced and nobody answered. After the entry, the police went to defendant’s wife and told her of the entry and then asked her for consent to search, and that search revealed evidence not found before. The government proved attenuation from the illegal search and a later statement. United States v. Sanchez, 2017 U.S. Dist. LEXIS 43631 (M.D. Pa. March 24, 2017).
The change in the law about GPS installation doesn’t entitle a 2255 petitioner to relief or show IAC. Curbelo v. United States, 2017 U.S. Dist. LEXIS 44188 (M.D. Fla. March 27, 2017).*