Defendant’s 2255 Franks IAC claim fails for not showing what the false statements were and how probable cause was undermined. United States v. Johnson, 2017 U.S. Dist. LEXIS 112806 (D. Md. July 20, 2017).
Defendant’s moving his hands around in a vehicle prior to getting out supported a frisk. United States v. Davis, 2017 U.S. Dist. LEXIS 112912 (S.D. W.Va. July 20, 2017).*