Appellate counsel can’t be ineffective for not arguing a Fourth Amendment claim not presented to the trial court. Peterson v. State, 2017 Fla. LEXIS 1455 (July 6, 2017).
Defendant didn’t have standing to challenge the search of the car he was in, so defense counsel wasn’t ineffective for not filing a motion to suppress. Gonzalez v. United States, 2017 U.S. Dist. LEXIS 103835 (E.D. Mich. July 6, 2017).*
In a bank robbery case, defendant failed to show a Franks violation that the search warrant had false information in it. United States v. Lomas, 2015 U.S. Dist. LEXIS 189269 (S.D. Iowa April 14, 2015).*