An officer with a package and an anticipatory search warrant did not violate the curtilage by entering through defendant’s screen door to approach the front door when he could see that there were other packages on a table by the door. It was reasonable to approach the front door to knock. When defendant accepted the package on the patio, the triggering condition for entering the house was satisfied without the package actually going into the house. United States v. Matthew, 2018 U.S. App. LEXIS 3998 (9th Cir. Feb. 20, 2018).
Defendant’s 2254 claim of defense counsel’s failure to investigate a Franks challenge is defaulted for not having presented it to the state court first. Simmons v. Sec’y of the Fla. Dep’t of Corr. & Fla. Ag, 2018 U.S. Dist. LEXIS 26360 (M.D. Fla. Feb. 20, 2018).*