The exclusionary rule does not apply to revocation of supervised release. United States v. Phillips, 2018 U.S. Dist. LEXIS 25603 (C.D. Ill. Feb. 16, 2018).
Defendant’s 2255 Fourth Amendment IAC claim wasn’t timely: “Petitioner’s motion to vacate was not filed until October 20, 2014; this is more than one year after his conviction became final. Petitioner has not asserted an argument for equitable tolling. Therefore, Petitioner’s motion is untimely and must be dismissed.” Loper v. United States, 2018 U.S. Dist. LEXIS 25651 (E.D. Mo. Feb. 16, 2018).*
Even if the GPS evidence was illegally obtained (it wasn’t), there was independent probable cause for defendant’s arrest. The CI was independently corroborated. United States v. Goode, 2018 U.S. Dist. LEXIS 25547 (S.D. N.Y. Feb. 16, 2018).*