A search warrant affidavit doesn’t have to be headed “affidavit” to be one, and the attachments are considered sworn to if referred to in the body. The affidavit’s typo of having the 16th as the date of the offense when it was the 15th is not a constitutional error because it was obvious what was meant. United States v. Jackson, 2018 U.S. Dist. LEXIS 97668 (S.D. Ill. June 11, 2018).
Defendant’s post-conviction Franks claim fails for not showing intentional disregard or materiality. Djenasevic v. United States, 2018 U.S. Dist. LEXIS 98527 (M.D. Fla. June 12, 2018).*