The narcs timed execution of a search warrant for when defendant’s heroin dealer would arrive. He was near the front door when the police arrived, and he could be detained under Summers and Bailey. United States v. Jones, 2018 U.S. Dist. LEXIS 75932 (E.D. Va. May 4, 2018).
Nothing was seized in the search warrant for defendant’s property that was used at his trial. Therefore, counsel couldn’t be ineffective for not challenging the probable cause for the search warrant. United States v. Fuentes, 2018 U.S. Dist. LEXIS 75314 (W.D. Wash. May 4, 2018).*