Defendant was in custody, handcuffed and on the ground, but his wife showed up acting somewhat belligerent. Her presence satisfied exigency for the car search. United States v. Beene, 2018 U.S. App. LEXIS 11400 (5th Cir. May 2, 2018).
Defense counsel wasn’t ineffective for not challenging the informant probable cause because it would have failed. The claim that the apartment number in the warrant was changed at the scene from 4 to 3 was without evidentiary support and fails. It appears to be a mere typo. Pate v. State, 2018 Iowa App. LEXIS 444 (May 2, 2018).*