E.D.Va.: Suit over opening medical records envelope as non-legal mail was frivolous

Suit over opening of non-legal mail, here medical records, was frivolous. Villafana v. Clarke, 2018 U.S. Dist. LEXIS 54893 (E.D. Va. Mar. 30, 2018).

The first officer at the scene conducted a search without probable cause. A supervising officer appeared at the scene and recognized defendant as being on probation or parole. Thus, inevitable discovery applies. United States v. Jones, 2018 U.S. Dist. LEXIS 53664 (C.D. Cal. Mar. 30, 2018).*

Defendant’s Franks challenge is “silly.”: “Considering the level of Maurice’s first-hand knowledge regarding the trap house and its contents as recounted in the affidavit, Defendants’ argument is silly.” United States v. Green, 2018 U.S. Dist. LEXIS 54031 (E.D. Pa. Mar. 30, 2018).*

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