The dashcam video doesn’t support what the officer testified to seeing, but it was a different angle, and the court finds that people can see what a video cannot (citing authority). The audio supports the officer’s basis for the stop, and then the smell of marijuana justified the search. United States v. Carter, 2017 U.S. Dist. LEXIS 169770 (D. Minn. Sept. 20, 2017), adopted, 2017 U.S. Dist. LEXIS 169372 (D. Minn. Oct. 12, 2017).
Defendant’s Fourth Amendment claim via 2255 is summarily denied because it was already covered by the appeal. United States v. Curran, 2017 U.S. Dist. LEXIS 170869 (M.D. Pa. Oct. 16, 2017).*