CA11: Def counsel wasn’t ineffective for not pursuing suppression motion after def admitted facts showing no standing

Defense counsel wasn’t ineffective for not adequately pursuing defendant’s motion to suppress because defendant admitted to counsel facts after the motion was filed that he had no standing at all. He provided that address as his address, but he was only there for commercial distribution of marijuana, thereby further linking himself to the address for guilt purposes. Campbell v. United States, 2018 U.S. App. LEXIS 14717 (11th Cir. June 4, 2018).

The affidavit for the arrest warrant was insufficient for lack of particular facts, but the officer still relied on it in good faith. The search of the car was justified by inventory or the automobile exception, so defendant’s alleged lack of standing is moot. State v. Jackson, 2018-Ohio-2131, 2018 Ohio App. LEXIS 2323 (8th Dist. June 4, 2018).*

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