Defendant had a Franks challenge and lost. One 2255 claim is that if defense counsel investigated more, it would have been a better Franks motion, but he fails to state what else would have been found to make it better. That’s clearly insufficient for 2255 or Franks. United States v. Anderson, 2018 U.S. Dist. LEXIS 8587 (D. Md. Jan. 19, 2018).
Defendant arranged a hookup to meet and video a child for sex through Craiglist and Kik Messanger app. The search warrant for child pornography at his house was not “so lacking” in a factual basis for its issuance that it should be suppressed. The messages indicated he was planning on making child pornography at the meeting, and it’s not a stretch that he had in the past. The vehicle search warrant thus also permitted seizure and forensic evaluation of a hard drive found in his car. United States v. Whisman, 2018 U.S. Dist. LEXIS 8049 (E.D. Tex. Jan. 18, 2018).*