OH8: 4A IAC claim requires defendant allege and offer proof of standing

Defendant doesn’t allege any facts to support that he had standing such that a motion to suppress would be granted. Therefore, no IAC shown. State v. Musleh, 2017-Ohio-8166, 2017 Ohio App. LEXIS 4533 (8th Dist. Oct. 12, 2017).*

Defendant’s 2255 claim that defense counsel didn’t move to suppress isn’t IAC because defendant had no standing. United States v. Park, 2017 U.S. Dist. LEXIS 170995 (D. Kan. Oct. 16, 2017).*