CA6: Alleged defect in state arrest warrant was irrelevant under the 4A where there was PC

Defendant’s arrest under a purportedly defective Georgia arrest warrant was irrelevant under the Fourth Amendment because there was plenty of probable cause for it. Specifically, defendant contended that the officers needed an incident report or something that showed probable cause and couldn’t rely on the judicial finding of probable cause, which they obviously could. Defendant was not entitled to a Franks hearing because of an immaterial omission to the finding of probable cause; even if it had been disclosed, the search warrant would still have issued. United States v. Sweeney, 2017 U.S. App. LEXIS 19482 (6th Cir. Oct. 3, 2017).

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