WA: Def’s new crime of obstruction wasn’t subject to suppression for illegal arrest

There is no general obligation to cooperate with the police, but there is a duty not to resist an arrest. Defendant’s obstruction was a new crime not subject to a motion to suppress for the alleged prior illegality of the arrest. Defense counsel wasn’t ineffective for not filing a motion to suppress for strategic reasons, and it would have lost on the merits anyway. State v. D.E.D., 2017 Wash. App. LEXIS 2135 (Sept. 19, 2017).

District court did not clearly err in finding consent to search. United States v. Songlin, 2017 U.S. App. LEXIS 18283 (4th Cir. Sept. 21, 2017)* (Anders brief); United States v. Rogers, 2017 U.S. App. LEXIS 18350 (5th Cir. Sept. 22, 2017).*

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