Pinging defendant’s cell phone to locate him after an arrest warrant issued didn’t implicate the Fourth Amendment. There was also exigency from fear for safety of the CI and of destruction of evidence. United States v. Sauceda, 2017 U.S. Dist. LEXIS 170747 (D. S.D. Sept. 27, 2017).
Defendant’s IAC claim for not challenging a search fails simply because he stated at his guilty plea that he was satisfied with his defense counsel’s advice. Britain v. State, 2017 Miss. App. LEXIS 602 (Oct. 17, 2017).*