Where the motion to suppress was filed the Friday before a Monday bench trial, it was within the discretion of the district court to defer the suppression motion ruling until after all the evidence was in. United States v. Hardison, 2017 U.S. App. LEXIS 10531 (8th Cir. June 14, 2017).
Failure to move to suppress until mid-trial was a waiver. It’s in the district court’s discretion to decide it on the merits or treat it as waived. United States v. Walker-Couvertier, 2017 U.S. App. LEXIS 10633 (1st Cir. June 15, 2017).