Defendant was locked in an interview room, and the trial court’s findings he was there and remained there by consent was clearly erroneous. Any error, however, was harmless in light of the overwhelming evidence of guilt. State v. Hawkins, 2017 Tenn. LEXIS 272 (May 1, 2017).
Defendant consented to entry of one officer, not two, but relented when he was told it was for officer safety. That was consent as to the second. State v. Palmer, 2017-Ohio-2639, 2017 Ohio App. LEXIS 1650 (9th Dist. May 3, 2017).*
Defense counsel argued defendant’s suppression motion at trial and on appeal. His argument now is that defense counsel should have argued that defendant had standing to refuse the search. Since the search was valid, this issue doesn’t matter. Irons v. United States, 2016 U.S. Dist. LEXIS 186351 (N.D. W.Va. Aug. 9, 2016),* adopted, COA denied, 2017 U.S. Dist. LEXIS 66588 (N.D. W.Va. May 2, 2017).*