A citation or summons is not an “arrest” in common usage or in the single arrest situations in application of the U.S. Sentencing Guidelines. United States v. Ley, 2017 U.S. App. LEXIS 23637 (3d Cir. Nov. 22, 2017).
Defendant didn’t even attempt to show that the search warrants in this case were issued without probable cause or executed unreasonably. Therefore, he can’t succeed on his ineffective assistance of counsel claim. United States v. Chappell, 2017 U.S. Dist. LEXIS 187982 (D. Minn. Nov. 14, 2017).*